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We don't find this topic discussed much, so we were interested to discover the author's thoughts.
He considers this to be a legal dispute with the Devil. We don't agree. God does not engage in legal negotiations with the Devil. There was no legal principle at stake. God did not consider the validity of the Devil's claims. This is not a legal matter, despite the author's speculations to the contrary.
Rather than law, we think the actual context is position, authority, and glory. Let's consider some of these concepts and how they might relate to the subject. First, let's quote a bit more of Jude than does the author:
Notice the context is about certain men who don't know their place and therefore slander celestial beings. They are contrasted with the angels who dared not slander these beings. Angels dare not do what arrogant men do.Jude 8-9 In the very same way, these dreamers pollute their own bodies, reject authority and slander celestial beings. 9 But even the archangel Michael, when he was disputing with the devil about the body of Moses, did not dare to bring a slanderous accusation against him, but said, “The Lord rebuke you!”
Who are celestial beings (literally, "glorious ones")? The Greek word for "celestial" is doxa: angels are called doxa as being spiritual beings of preeminent dignity... opinion, estimate, whether good or bad, concerning some one; good opinion concerning one, and as resulting from that, praise, honor, glory.
They are beings arrayed in splendor, magnificent in nature. But they are not necessarily holy. Some are glorious but fallen. They are not as strong and powerful as angels, perhaps due to their fallen status, yet even then the angels do not bring accusation.
This concept comes up again in second Peter:
2Pe. 2:10-11 This is especially true of those who follow the corrupt desire of the sinful nature and despise authority. Bold and arrogant, these men are not afraid to slander celestial beings; 11 yet even angels, although they are stronger and more powerful, do not bring slanderous accusations against such beings in the presence of the Lord.
The angels respect them. And clearly these beings are not holy, for otherwise, why would angels have the potential to bring slanderous accusations against them?
"Slander" is blasphémeó, which is in this context means, to be evil spoken of, reviled, railed at... Whether good or bad, it is clear that the celestial beings are not to be slandered. Imagine, an evil celestial being should not be slandered.
Both Jude and Peter are writing in the context of arrogant men. These "dreamers" who "despise authority" are not slow to slander celestial beings, even though the angels dare not do so. Michael himself, an archangel, would not even do so with the devil!
We would conclude that the devil is one of the celestial beings, who has a glory (doxa) even in his fallen state. This suggests that Christians should not engage in slander, taunting, or disrespect against the enemy. Those who think they would "bind" the enemy risk slandering a celestial being, something even the angels refuse to do.
Without question, one of the strangest verses in the Bible is Jude 9: But Michael the archangel, when he disputed with the devil about the body of Moses, did not dare pronounce against him a railing judgment, but said, “The Lord rebuke you!” Questions have long swirled around this verse, and the death and burial of Moses in general.
The canonical record of the death and burial of Moses is shrouded in mystery in Deuteronomy 34. Verse 1 says, “Now Moses went up from the plains of Moab to Mount Nebo, to the top of Pisgah, which is opposite Jericho. And the LORD showed him all the land, Gilead as far as Dan.” A few verses later, verses 5-6 add, “So Moses the servant of the LORD died there in the land of Moab, according to the word of the LORD. And He buried him in the valley in the land of Moab, opposite Beth-Peor; but no man knows his burial place to this day.” After seeing the Promised Land from afar, Moses died alone in the presence of the Lord. Then something mysterious happened: Moses did not have a normal funeral and burial. The text says that “He” – presumably Yahweh – buried Moses in a secret grave. Nothing in this chapter mentions the devil, Michael, or a dispute about Moses’ body.
The mysterious nature of Moses’ burial proved to be fertile soil in which Jewish speculations and legends would grow. One source of discussion was a Jewish work entitled The Assumption of Moses. Another Jewish text called The Testament of Moses also mentions these events, although scholars are divided whether these were two separate works or the same work under two different titles. Whatever the case, the text of these writings is incomplete, and the part that refers to Moses’ burial has been lost. We only know that these writings speak about Moses’ burial from early church scholars who referenced these works. To complicate matters further, Jude might never have seen these writings and could have been referring to an oral tradition familiar to his original readers. Regardless of the specific source, we can conclude that Jude’s readers knew about this tradition since Jude assumes they understand what he is discussing without further context.
One commonly asked question about Jude’s inclusion of this Jewish tradition is why the Bible would incorporate something non-canonical into the sacred text. Does that mean that the original text or tradition Jude references was the inspired Word of God? No, just because the Bible quotes a non-inspired text or refers to an oral tradition not found in Scripture does not mean those texts and traditions were inspired by God. The Bible is a historical book, which means it will include historical facts that may be found in other writings or traditions. The biblical writers were moved by the Spirit to include those non-inspired texts or traditions in the inspired text of Scripture because those texts or traditions were historically accurate and reflected the truth God wanted to communicate in that portion of Scripture about that historical event. Therefore, we can conclude that Jude’s inclusion of this story about Michael and the devil is historically reliable since the Spirit of God moved Jude to include it in the New Testament as a historical account. The way it is worded in Jude is exactly as the Spirit wanted it to be articulated so that we have a true description of what happened.
After Moses’ death, there was a dispute about his body that arose between the devil and Michael the archangel. But why? The most plausible explanation comes from Richard Bauckham, who argues that the devil disputed with Michael about the body because Moses was a sinner. Furthermore, Moses was not just any sinner, but he was a murderer. In Exodus 2:12, Moses killed an Egyptian for beating one of the Hebrews. The devil therefore laid claim to Moses’ body, and such a claim was meant to be not only over Moses’ body but over his soul. Because Moses had so flagrantly violated the law of God, he stood condemned. This explanation comports well with what we know of the devil, who is also called the accuser of the brethren in Revelation 12:10.
The dispute in Jude 9 was not merely an argument, but the Greek words Jude employs speak of a legal battle. The devil was laying legal claim to Moses based on Moses’ sin. We see something similar in Zechariah 3:1. Joshua the High Priest of Israel is standing before the angel of the Lord, and Satan stands at the right hand of Joshua to accuse Joshua of sin before the Lord. This accusation was not unfounded, for Zechariah 3:3 tells us that Joshua was standing before the Lord in filthy garments, representative of his sin and guilt before the Lord. Satan’s claim appeared to be legally valid at first because Joshua was indeed a sinner who deserved condemnation. God, however, provided Joshua with festal robes, replacing his guilt with the Lord’s own justifying righteousness. In a similar fashion, the devil is making a legal claim against Moses, that Moses deserves to be condemned for his sin. Such an accusation against the servant of the Lord demands a clear response.
Michael, who is described as one of the chief defenders of the people of God in Daniel 12:1, responds to the devil, but perhaps not in the way we might expect. Ironically, Moses is not the one who stands condemned before the Lord, but the devil who accuses Moses is the wicked one under God’s judgment. Michael the archangel might have rebuked Satan directly, seeing his wickedness in seeking to bring condemnation on Moses. However, Jude tells us that Michael “did not dare pronounce against him a railing judgment.” Given the legal context of this verse, Jude means that Michael did not issue a legal condemnation against the devil. Certainly, the devil stands condemned before God, but Michael did not presume to step into God’s role as the one who judges the wicked. Although he was the archangel with so much power among the hosts of heaven, Michael recognized God had prescribed limits to his authority, limits that he must respect for the honor and glory of the Lord.
Michael’s response, “The Lord rebuke you,” is identical to what the angel of the Lord said to Satan in Zechariah 3:2, indicating that this tradition was closely linked to that account as well. This response, as Thomas Schreiner has aptly noted, does not mean that Michael is asking the Lord to give Satan a verbal “dressing down.” Instead, Michael is calling upon the Lord to render His righteous judgment in the legal dispute over Moses’ body. Michael is asking the Lord both to vindicate His servant Moses and to condemn the accuser of the brethren, the devil. Michael’s response models a true and proper faith in God’s justice. The one who believes God will judge righteously need not condemn the wicked, not even the devil, nor does he need to vindicate himself. Instead, he can rest, knowing the Lord Himself will vindicate His people and condemn the wicked.
In the context of Jude, Michael’s humble trust in God’s justice stands in stark contrast to the false teachers who are described as reviling in verses 8 and 10. They “reject authority, and revile angelic majesties,” and they “revile the things which they do not understand.” They do not tremble to take the place of God by establishing themselves and their opinions as the standard of judgment, and they arrogate to themselves the prerogative to justify and to condemn based on their imagined standard of righteousness.
True believers by contrast lives humbly before God, recognizing that our role is not to establish the standard of righteousness or to judge whether others have achieved that standard. Our responsibility is rather to submit to God’s standard of righteousness, to proclaim it according to His Word, and to leave the final judgment of others where it belongs – in the hands of the one true Lawgiver and Judge.
This mysterious passage proves quite relevant and powerful, reminding us humbly to obey our Lord by faith, resting in the truth that the Judge of all the earth will do what is right. Furthermore, it provides immense comfort to the believer. The devil will accuse us of sin and guilt, but our Lord has overcome our sin and guilt at the cross, so that none of his accusations against us will stand. We have been clothed with Christ’s righteousness, and all our filthy garments were buried in a grave no one will ever find.
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