Although the treatment approach to sentencing is still significant in modern legislation, it has been seriously handicapped by two main factors: (1) The recent return to more punitive approaches to offenders; and (2) The ruling that efforts at providing treatment through sentencing are as much subject to the restraining doctrine of proportionality as is punishment. It remains a paradox that the sentencer also is acting in the interests of the offender when he/she responds to the law's insistence that court-ordered efforts at rehabilitation not be excessive. It can only be hoped that this legal constraint does not inhibit the continued development of more creative, constructive, and experimental ways of addressing crime and assisting offenders under the rehabilitative model. Treatment is the more benevolent and humane of the competing sentencing approaches, and evidence suggests that it is more cost-effective than sentencing that focuses on retribution, deterrence, and incapacitation. 46 notes