What can justify taking freedom away as a form of punishment? In other words, what reasons can be given for restraining people. removing liberty in the negative sense? As we have seen in the previous section, the notion of positive freedom can be used to justify coercing individuals in some ways: only by being protected against themselves can such people achieve true freedom. Philosophers have attempted to justify state punishment of individuals in four main ways: as retribution, as deterrent, as protection for society, and as reform of the person punished The first is usually defended from a deontological position; the other three typically on consequentialist grounds.