In Burlison v. State, 501 S.W.2d 801 (Tenn. 1973), the Court held that when the proof shows multiple offenses which could each sustain the allegations of the criminal charge, it is "the duty of the trial judge to require the State, at the close of its proof-in-chief, to elect the particular offense of carnal knowledge upon which it would rely for conviction, and to properly instruct the jury so that the verdict of every juror would be united on the one offense." Id. at 804. This requirement is "fundamental, immediately touching the constitutional rights of an accused, and should not depend upon his demand therefor." Id. The supreme court in Burlison maintained that election is necessary to: (1) enable the defendant to prepare for and make his defense to a specific charge; (2) protect the defendant from double jeopardy by individualizing the issue; (3) prevent a less than unanimous jury verdict in which some jurors convict on one offense and others on another. Id. at 803. The Court held that it is "the duty of the trial judge to require the State, at the close of its proof-in-chief, to elect the particular offense of carnal knowledge upon which it would rely for conviction, and to properly instruct the jury so that the verdict of every juror would be united on the one offense." The duty to require election exists on the part of the trial court even in the absence of a specific request by the defendant. Id. The Burlison court enumerated three reasons underlying the election requirement: "First, to enable the defendant to prepare for and make his defense to the specific charge; second, to protect him from double jeopardy by individualization of the issue; and third, so that the jury's verdict may not be a matter of choice between offenses, some jurors convicting on one offense and others, another." (Id. at 803.) Burlison involved various allegations of sexual misconduct. The reasons for requiring election in cases that contain evidence of numerous instances of unlawful conduct is to enable the defendant to prepare for and make his defense to the specific charge; to protect him from double jeopardy by individualization of the issue; and to insure that the jury's verdict may not be a matter of choice between offenses, some jurors convicting on one offense and others, another. Id. at 803.