Easton's Bible Dictionary: M. G. Easton, M.A., D.D.
As a punishment were not to exceed forty (Dt. 25:1-3), and hence arose the custom of limiting them to thirty-nine (2 Cor. 11:24). Paul claimed the privilege of a Roman citizen in regard to the infliction of stripes (Acts 16:37, 38, 22:25-29). Our Lord was beaten with stripes (Mt. 27:26).