 Third, it is not clear whether forfeiture theories that do not appeal to desert can make sense of the proportionality restrictions that are central to retributivism (Duff 2001: 14–16). Indeed, the proportionality limits of a pure forfeiture model, without desert, may be quite different from the limits implicit in the notion of deserved punishment. A pure forfeiture model arguably would limit hard treatment only to ensure that penalties strike a fair balance between the claims of individuals not to have to bear them and the claims of the state to take effective measures to promote important public ends. All the concerns with the gravity of the wrong seem to go missing (Walen forthcoming). To cite the gravity of the wrong to set proportionality limits seems to presuppose some fundamental connection between the gravity of the wrong and proportional punishment (see  section 4.4).  That connection is naturally picked up with the notion of deserved punishment. If one eschews that notion, it is not clear how to make the connection.