Deuteronomy 25:3

Forty stripes he may give him, and not exceed, this precept later resulting in the limit's being placed at thirty-nine, for there was danger of miscounting, and the Jews, especially after the return from the exile, were anything if not literal, 2 Corinthians 11:24; lest, if he should exceed and beat him above these with many stripes, then thy brother should seem vile unto thee, lowered beneath the dignity of a man and a member of God's people. The punishment by whipping was in use also in Egypt, where the culprit was laid flat on the ground, his hands and feet held firmly, and the punishment administered on the back in the presence of the judge.