QUESTION: As a punishment for not properly carrying out his duty, the angel Gavriel was punished with "sixty bursts of fire." The Gemara in other places mentions this punishment in reference to angels (see, for example, Chagigah 15a and Bava Metzia 85b). What is the significance of sixty lashes?
ANSWER: According to one opinion in the Rishonim, "Makos Mardus" -- lashes mandated by the Rabanan for transgression of a rabbinical prohibition, are comprised of only 13 lashes, instead of 39 which comprise Malkus d'Oraisa (TASHBETZ 2:51, citing RASHI in Yevamos 52a; SHILTEI GIBORIM on the Mordechai to Bava Basra, end of Perek Yesh Nochlim, citing RABEINU TAM). (See Insights to Chulin 141:4 with regard to the differences between Malkus d'Oraisa and Malkus d'Rabanan.)
The TERUMAS HA'DESHEN (in Bi'urim on the Torah, end of Parshas Ki Setzei, as cited by the BACH on the Rif to Kesuvos, page 16b of the pages of the Rif; see also MAGEN AVRAHAM OC 496:2) explains this opinion as follows. The Mishnah in Makos (22a-b) describes the 39 lashes of Malkus d'Oraisa as three sets of 13 lashes. Two sets are administered on the person's back and one set on his chest. The Terumas ha'Deshen explains that this means that the actual number of lashes that should be administered is only 13, to correspond to the first 13 years of a person's life during which he is expected to learn to make the proper decisions. If he sins, this shows that he failed to learn to make the proper decisions as he was maturing, and thus he is punished with 13 lashes. However, the Torah prescribes two additional sets of 13 lashes on two other parts of his body as an additional penalty. (One set of lashes is given opposite his heart, the place where his thoughts originate, and two sets are given opposite his two kidneys, which counsel the body as to what actions to take.) The Rabanan do not have the prerogative to add two extra sets of lashes because their enactments themselves are already added penalties or restrictions, and the Rabanan cannot impose one penalty on top of another. Therefore, for the transgression of an Isur d'Rabanan only 13 lashes are administered.
A similar logic applies to punishments administered to angels. Although a person becomes accountable for his actions with regard to punishments in the hands of the worldly Beis Din at the age of 13, he is not accountable with regard to punishments at the hand of the "heavenly court" until the age of 20 (Shabbos 89b). Hence, when the heavenly court administers Malkus, it is in the form of 20 lashes repeated three times (like the lashes of the worldly courts), for a total of 60 lashes.