Other scholars use the retribution theory is the basis for supporting the death penalty. Under the retribution theory, the proponents argue that fundamentally, criminals deserve punishment that is proportionate to the offense committed. The theory of proportional punishment has elicited contradicting perspectives although the fundamental basis is that retribution is a rational approach which has the potential to deter criminal tendencies. Retribution is generally a concept of justice and is different from revenge which is based on emotions of hatred. Based on the retribution approach, the murderer put on death penalty gets a deservedly punishment as reflected in the lex talionis. Why the society should be forced to keep criminals in jails and prisons paying for their foods, their shelter and security. Matters get complicated given that most victims and the general public live in in an environment of fear whenever such criminals are loose either by unlawful escape from custody or judicial release from custody. There are arguments that serial killers and murderous have escaped from custody in the past committing more crimes. The proponents of the death penalty argue that the most effective way of punishing killers is to put them on the death penalty. Similarly, proponents of the death penalty argue that criminals facing death row are given fair trial and the appeal processes is kind to convicts as opposed to the ordeals that the victims go through. The convicts have the opportunity to appeal and make last wishes; the victims have no such pleasure.