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If the teacher had caught him cheating and this had resulted in a failing (0) grade for the paper including the humiliation he would have brought on himself, you may refrain from a consequence for the time being. Instead, talk to him about why this behavior is not acceptable and what can be other harsh consequences in his life should he resort to dishonesty in general. Find out his side of the story. Was he unprepared, nervous, did not remember that there will be a test, did not understand the work etc.