This one could be "who" http://www.paulgraham.com/perils.html apart from that I agree.
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My understanding is that "whom" is the indirect object of the verb "punish," so this would be correct as "whom." An imperfect heuristic I use is to replace "who" with "he/she/they" and "whom" with "him/her/them" and see if it works: "He may punish whom?" "He may punish him."
End of conversation
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