The purpose of this paper is not to try to establish from first principles the meanings of the terms employed by Paul in connexion with justification, but the much more modest one of simply indicating what we understand to be the correct interpretation of the terms and briefly defending this against some other interpretations.

Taking the verb dikaioun/dikaiousthai first, we understand that the active form means ‘to pronounce or declare righteous, to accept or treat as righteous’, and that the passive form has the corresponding sense of ‘being pronounced and treated as righteous’.¹ The basic idea is a forensic one. This is emphasized both by Protestant exegetes like G. Schrenk, who writes: ‘It may be conceded that the usus forensis is not given prominence in every passage by express emphasising of the judicial act.… Yet the idea of judgment is everywhere present’,² and L. Morris, in whose opinion ‘there is an ineluctable forensic element … whenever St Paul uses the term’,³ and by the Catholic theologian H. Küng, who in a similar vein says: ‘The idea of an act like that of a court is indeed not universally present, yet the association with a juridical situation is never absent.’⁴ We further agree with those who say that dikaioun cannot mean ‘to make righteous’ in the ethical sense of making virtuous.⁵ Thus G. Schrenk rightly points out that ‘for Paul the word dikaioun does not suggest the infusion of moral qualities, a justum efficere in the sense of the creation of right conduct’.⁶ While it is possible, on the analogy of other verbs ending in—oō (e.g. typhloō, douloō), to accord the word dikaioō a factitive or causative force (‘to make dikaios’), ‘this meaning is extremely rare, if not altogether doubtful’.⁷Moreover, dikaioō belongs to that group of—oō verbs which are ‘derived from adjectives of moral as distinguished from physical meaning’, where the sense is ‘to regard as, to treat as, not to make’;⁸ axioō, for example, never means ‘to make worthy’, but always ‘to account, to judge, to declare, to treat as worthy’.⁹ Even more important than analogies with other words is the actual usage of the verb in the Septuagint¹⁰ and in Paul,¹¹ which seems to favour the view that it denotes basically a declaratory act rather than a making righteous.¹² Hence we believe that dikaioun is to be understood in its declarative rather than strictly causative sense.

The noun dikaiosynē denotes in a moral and religious sense the characteristic required of men by God, fulfilment of the divine commands and uprightness of conduct, and is sometimes so used in Paul;¹³ this ethical sense is not, however, his characteristic or distinctive use of the term. In specifically Pauline thought, and corresponding to the judicial, declarative sense of dikaioun, the noun dikaiosynē signifies what is variously described as ‘the righteousness bestowed by God’,¹⁴ ‘acceptance with God’,¹⁵ or ‘a standing with God, … a status conferred on man by God on the grounds of the atoning work of Christ’.¹⁶ What appears in view in the specific use of dikaiosynē, then, is a man’s personal standing before God. Similarly, the dikaios is one who is acceptable with, approved of, and accepted by God;¹⁷ to put it differently, he is one who is put in the right with God, who is declared righteous by him.¹⁸

In brief, we concur with L. Morris and others in holding ‘that justification is in essence a matter of right status or standing in the sight of God, the status which shows that we are accepted with Him’.¹⁹ We turn next to a few proposals in connection with justification which differ in one way or another from the view accepted above.

1. E. J. Goodspeed

Goodspeed believes that dikaioun in Romans 3:26, 30; 4:5; 8:30, 33; Galatians 3:8 and elsewhere is to be given the sense ‘to make upright’.²⁰ On the basis of Psalm 72:13 (lxx: edikaiōsa tēn kardian) and Isaiah 50:8 (lxx: hoti engizei ho dikaiōsas me), Goodspeed argues that the etymological presumption is with the sense ‘to make upright’, unless the context makes it impossible; and he speaks of the sense ‘to declare righteous’ as ‘a new sense unknown to the lxx or to classical Greek’.²¹ He further seeks to justify his rendering by appealing to the fact that the believer is a new creation and that his union with God provides him with an escape from sin and the sinful nature.²²

As regards ‘etymological presumption’ in general, A. B. Davidson has warned that ‘etymology is rarely a safe guide to the real meaning of words’ and ‘usage is the only safe guide’.²³ Turning to the particulars, we may note that in Isaiah 50:8 the twice-repeated tis ho krinomenos moi? distinctly suggests that dikaiōsasshould be given a judicial sense; and even though edikaiōsa in Psalm 72:13 is used in a moral sense,²⁴ this is hardly sufficient to establish the meaning ‘to make upright’ for dikaioō and to overthrow what B. M. Metzger calls ‘the unmistakable evidence of the meaning of this verb in the Pauline epistles’.²⁵ As for the assertion that the sense ‘declare righteous’ is ‘unknown in the lxx’, sufficient refutation is provided by such references as Exodus 23:7 (where the judge is told, ou dikaiōseis ton asebē heneken dōrōn), Deuteronomy 25:1 (where Moses directs that the judges dikaiōsōsin ton dikaion kai katagnōsin tou asebous), and Isaiah 5:23 (where a woe is pronounced on the dikaiountas ton asebē heneken dōrōn kai to dikaion tou dikaion airontas). For in these passages, it just would not do to give dikaioun the meaning ‘to make upright’; some such sense as ‘to acquit or declare righteous’ alone fits the context. Finally, Goodspeed’s appeal to the believer’s being a new creation in union with God is ineffective, for the most it could do is to confirm the meaning of dikaioun as ‘to make upright’ if this could be established independently; but, as we have seen, the facts rather point away from such a conclusion. Hence Goodspeed’s bold and novel attempt must be considered unsuccessful.

2. C. K. Barrett

Barrett²⁶ argues that it is ‘more in harmony with Paul’s teaching as a whole to suppose that “to justify” (dikaioun) does mean “to make righteous” ’ though ‘righteous’ here means not ‘virtuous’, but ‘right’, ‘clear’, ‘acquitted’ in God’s court. Barrett describes ‘the most popular modern interpretation of the Pauline verb “to justify” and the Pauline doctrine of justification’ as follows: ‘The verb means “to count, or treat as, righteous”. Justification means that God treats sinful men as if they were of complete and unstained virtue.’²⁷ He then proceeds to bring ‘two radical objections’ against this interpretation. The first objection is linguistic: the hiph‘il form of the Hebrew verb lying behind dikaioun (hiṣdîq) is regularly causative in meaning and cannot possibly be weakened so far as to mean ‘to treat as righteous’. But that the Hebrew verb in question can be and is used in the sense ‘to declare righteous’ rather than ‘to make righteous’ is obvious from the passages already referred to in the last paragraph: Exodus 23:7; Deuteronomy 25:1; Isaiah 5:23—in each case a form of the verb ṣdq in the hiph‘il is used.²⁸

The second objection is doctrinal:

It may be said that this account of justification must lead either to Pelagianism (since faith itself will be treated as a righteous work, or at least as righteousness in germ), or to the kind of legal fiction which men feel instinctively is not legitimate even for God, if he be a moral being. Not even he may pretend that black is white.

This objection indeed applies to the popular interpretation as described by Barrett, but it is not really applicable to the view we have accepted, since the latter does not involve treating faith as a righteous work or even as righteousness in germ; neither does it entail any kind of legal fiction or element of pretence. The latter point is borne out by the following statement of G. Schrenk:

Righteousness is forensically ascribed to the believer.… Forensically does not mean ‘as if’ he were righteous, since the sovereign sentence of God is genuinely pronounced. Nor does it mean that moral rectitude is attained. What it does mean is that the man who has dikaiosynē is right before God.²⁹

Barrett’s objections, therefore, would seem to be insufficient to require that dikaioun be taken to mean ‘to make righteous’.

3. H. Küng

If we have understood him correctly, Küng’s statements appear rather confusing. Thus, on the one hand, he rightly holds that ‘justification, following Sacred Scripture’s teaching, means a declaring just, a judicial event’,³⁰that ‘the term “justification” as such expresses an actual declaration of justice and not an inner renewal’,³¹ and that dikaiosynē is attributed ‘not as a quality, but as a relationship’.³² On the other hand, he maintains that ‘God’s declaration of justice is, as God’s declaration of justice, at the same time and in the same act, a making just’;³³ that when ‘God pronounces the verdict, “You are just,” … the sinner is just, really and truly, outwardly and inwardly, wholly and completely. His sins are forgiven, and man is just in his heart’.³⁴ This second set of statements is possible for Küng because he makes a distinction between two senses of ‘sanctification’—designated as, respectively, the Catholic understanding of it as ‘primarily the objective and ontological holiness (Heiligkeit) achieved in man by God’ and the Protestant emphasis on ‘subjective and ethical sanctification (Heiligung) brought about by man’—and identifies justification with sanctification in the former sense (i.e. ‘in the sense of an objective and ontological making holy brought about by God’).³⁵ Hence he can quite consistently go on to say:³⁶

God’s justification must be taken seriously; God does what he says. When God declares a man just, he draws him into the righteousness of God and thus he reflects (sic)³⁷ a transformation of man’s very being. When God says a man is just, since it is God who says it, man is simultaneously made just. From this it follows that justification includes in itself all the effects which touch the very being of the man who is justified, and his effective transformation, and thus also includes a positive sanctification effected by God.

It is important for our purpose to observe that Küng immediately adds this significant admission: ‘But it remains true that biblical and especially the Pauline act of justifying (“justification”) does not say this explicitly.’³⁸ Indeed, it may be questioned if Pauline justification says this even by implication. While, according to Küng, the ‘justice or holiness given to man through the justification of God (which) is the necessary foundation for any moral sanctification of man’³⁹ refers to sanctification in the objective and ontological, not subjective and ethical, sense, yet since even this sanctification is achieved ‘in man’ by God and makes man just ‘in his heart’, it is difficult to see how it could be regarded as only ‘objective’ and not ‘subjective and ethical’. If this reasoning is sound, then apart from his own admission already noted, it must be said against Küng’s understanding of the matter that while (keeping to Küng’s terminology) ‘the objective and ontological making-holy’ may well take place at the same time as ‘justification’, yet to regard it as taking place ‘through’ justification is to confuse justification with sanctification.⁴⁰

4. T. W. Manson

T. W. Manson⁴¹ disputes the legal sense of dikaioun and prefers to regard it as a regal act instead, stating that ‘in the Christian dispensation God’s dealing with the sinner is removed from the law court into the throneroom’.⁴² From Romans 4:2–8 Manson concludes that

‘justify’ in this sort of reasoning means not so much ‘declare righteous’ as ‘regard as righteous’, not so much ‘acquit’ as ‘lay no charge’ … He (i.e. God) doesn’t declare that the unrighteous is righteous, but treats him as if he were. It is amnesty rather than acquittal that is involved here—a regal rather than a judicial act.⁴³

Manson is also led, by the phrase chōris nomou in Romans 3:21, to remark:

‘Apart from law’ means what it says—that the proceedings are extra-legal.… But if the whole business is removed out of the sphere of law … and God acts not as administrator of the law but as king of his own kingdom and Father of his own children, then dikaioō may mean not pronounce righteous, but regard as righteous. God does not acquit the guilty, he issues an amnesty or free pardon.⁴⁴

In the light of the foregoing discussion, we venture the following criticisms. (i) In obtaining ‘light on what Paul means by dikaioō’⁴⁵ from only two or three passages, Manson has not done justice to other passages, where other exegetes clearly recognize the thought of a legal verdict (e.g. Rom. 8:33f.). (ii) When he says, ‘There is no sense in declaring a man righteous unless he is righteous’,⁴⁶ it is evident that he thinks of righteousness in the ethical sense; but if this is so, then even on his own showing an element of fiction is still involved in God’s treating (as distinct from declaring) the unrighteous as if he were righteous. On the other hand, it makes sense to speak of God’s declaring a man righteous if the meaning is that of conferring upon him a favourable standing, the question of his ethical righteousness not being in view at all.⁴⁷ (iii) It may be doubted that the phrase chōris nomou in Romans 3:21 can bear the weight of interpretation which Manson placed upon it, as indicating that the proceedings of justification are entirely removed from the sphere of law. While the absoluteness of the negation is set forth both by the phrase itself and by its emphatic position in the sentence, the negation refers not to the sphere in which the proceedings of justification take place, but simply to the alleged basis on which a man can be adjudged righteous. Choris nomou emphasizes the fact that ‘legal obedience contributes nothing to evangelic righteousness’;⁴⁸ but it does not thereby make justification an extra-legal processs. (iv) If regard is had to Pauline passages other than those referred to by Manson, it is difficult to interpret justification merely in terms of amnesty or free pardon. E. de W. Burton, while recognizing that ‘forgiveness is included in righteousness, either distinctly and explicitly, or by implication’—since in Jewish thought forgiveness of sins is a prerequisite for acceptance with God⁴⁹—roundly declares, ‘The reduction of Paul’s term, dikaioō, to a purely negative sense, “to pardon,” is definitely excluded by the evidence.’⁵⁰ As such evidence he refers to passages (e.g. Rom. 3:20, 28; 4:2; Gal. 2:16; 3:11; 5:4) in which erga nomou are explicitly mentioned as a ground of justification, though their adequacy as such a ground is equally explicitly denied. The context of these passages⁵¹ ‘makes it clear that works of law are thought of as inadequate not to secure the forgiveness of admitted sinners, but to win approval on ground of merit, which would leave no occasion for forgiveness’;⁵² this shows that the term dikaioun is not merely negative, meaning ‘to pardon’.⁵³

5. J. Jeremias

Jeremias⁵⁴ maintains that in the Pauline use of dikaioun ‘the figure of court proceedings is absent’. To Jeremias, ‘God’s justification is an outpouring of grace which far exceeds the legal sphere’, and ‘even though the forensic concept is by no means lacking … the soteriological connotation governs his speech’; he asserts that ‘as in the Pauline letters dikaiosyne (tou) theou must be translated “God’s salvation”, so dikaiousthai must be rendered, “to find God’s grace”.’⁵⁵ Again he writes:

Although it is quite certain that justification is and remains a forensic action, God’s amnesty,⁵⁶nevertheless the forensic image is shattered.… The forgiveness, the good pleasure which God grants, is not only negative, i.e. an effacement of the past, but it is an antedonation of God’s final gift.… As an antedonation of God’s final acquittal, justification is pardon in the fullest sense.⁵⁷

Jeremias sums up his position finally as follows:

It remains true that justification is forgiveness, nothing but forgiveness. But justification is forgiveness in the fullest sense. It is not a mere covering up of the past. Rather, it is an antedonation of the full salvation; it is a new creation by God’s Spirit; it is Christ taking possession of the life already now, already here.⁵⁸

There are two comments that we would venture on this understanding of justification. First, the emphasis upon justification being not merely negative pardon (as T. W. Manson apparently makes it) is well placed; but to explain justification as ‘a new creation by God’s Spirit’ and the indwelling of Christ would seem to be confusing God’s action over us on the basis of Christ’s work for us with the work of the Spirit in us. It is, in other words, as in the case of H. Küng, to confuse justification and sanctification, which, though inseparably linked together, are logically distinct from each other. Secondly, it is entirely true that in substance justification has to do with the salvation-grace of God and that the outpouring of grace ‘far exceeds the legal sphere’. This is well recognized and emphasized by G. Schrenk when he writes:

Naturally, the forensic element is only a figure for being righteous before God, and it is not to be pressed in terms of juridical logic. We are not now in the sphere of human jurisprudence. We are dealing with the divine Judge who is also the unlimited King. Hence the symbolic aspect … is not to be allowed to predominate by logically pursuing the forensic mode of apprehension. The legal aspect must be transposed at once into a divine key. The iustificatio iniusti is against all human standards. The content bursts the forms and an act of grace replaces customary legal procedure.⁵⁹

Nevertheless, it should not be overlooked that in form justification remains a forensic concept, as Jeremias himself concedes.⁶⁰

Having discussed above the various proposals made by E. J. Goodspeed, C. K. Barrett, H. Küng, T. W. Manson and J. Jeremias, we are perhaps justified in maintaining that the correct view of justification is that which regards it as primarily a legal concept having to do with the question of man’s acceptance with or standing before God.⁶¹

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¹ Cf. J. H. Thayer, A Greek-English lexicon of the New Testament (New York, n.d.), s.v. dikaioō, 3; Arndt and Gingrich, s.v. 3a; W. Sanday and A. C. Headlam, A critical and exegetical commentary on the epistle to the Romans (Edinburgh: T. and T. Clark, 1962), pp. 30f.; E. de W. Burton, A critical and exegetical commentary on the epistle to the Galatians (Edinburgh: T. and T. Clark, 1968), pp. 473f.; G. Schrenk, TDNT, II, p. 215; J. Murray, The epistle to the Romans I (Grand Rapids: Eerdmans, 1968), pp. 358ff.; L. Morris, The apostolic preaching of the cross² (London: Tyndale Press, 1960), pp. 224ff. passim.

² Schrenk, op. cit., p. 216.

³ Morris, op. cit., p. 260; cf. p. 259.

⁴ H. Küng, Justification (London: Nelson, 1964), p. 200; cf. pp. 201f., and especially pp. 292–295.

⁵ So, e.g., C. K. Barrett, The epistle to the Romans (London: A. and C. Black, 1973), p. 75; Sanday and Headlam, op. cit., p. 30.

⁶ Schrenk, op. cit., p. 215.

⁷ Thayer, op. cit., s.v. dikaioö, 1. Cf. Sanday and Headlam, op. cit., p. 31; Morris, op. cit., p. 226, n. 1; and especially C. H. Dodd, The Bible and the Greeks (London: Hodder and Stoughton, 1954), p. 48.

⁸ J. H. Moulton and W. F. Howard, A grammar of New Testament Greek, II (Edinburgh: T. and T. Clark, 1968), p. 397.

⁹ So Thayer, op. cit., s.v. dikaioō, 3; J. B. Lightfoot, Notes on epistles of St Paul from unpublished commentaries (London: Macmillan 1895), p. 105.

¹⁰ Cf. Dodd, op. cit., p. 52: ‘There are passages where hiṣdîq means to put a person in the right by declaring or judging him righteous, and while the lxx sometimes renders this by dikaion apophainein or krinein, in some cases where this meaning is required they use dikaioun’; he cites as examples Ex. 23:7 and Is. 5:23. Cf. N. M. Watson, ‘Some observations on the use of dikaioō in the Septuagint’, JBL 79 (1960), pp. 255–266.

¹¹ One cannot over-emphasize the importance of the insight expressed by Dodd, op. cit., p. 57: ‘The Pauline use of these terms dikaiosynē, dikaios, dikaioun must be understood in the light of Septuagintal usage and the underlying Hebrew. The apostle wrote Greek, and read the lxx, but he was also familiar with the Hebrew original. Thus while his language largely follows that of the lxx, the Greek words are for him always coloured by their Hebrew association.’ Cf. idem, The epistle of Paul to the Romans (London: Collins, 1970), p. 38.

¹² Cf. Schrenk, op. cit., pp. 212–214, 215f.; Morris, op. cit., pp. 233–235, 260, 261; J. A. Ziesler, The meaning of righteousness in Paul (London: Cambridge University Press, 1972), pp. 1, 58, 212.

¹³ Arndt and Gingrich, s.v. dikaiosynē, 2a, b.

¹⁴ Ibid., under 3.

¹⁵ Burton, op. cit., pp. 469–471.

¹⁶ Morris, op. cit., p. 258; cf. pp. 249, 250, 256. Cf. further, R. Bultmann, Theology of the New Testament, I (London: SCM Press, 1969), pp. 272, 285.

¹⁷ Cf. Burton, op. cit., p. 469; Thayer, op. cit., s.v. dikaios 1d.; Morris, op. cit., pp. 244, 246; B. Reicke, ‘Paul’s understanding of righteousness’, in Soli Deo gloria, ed. J. M. Richards (Richmond, 1968), pp. 37–49.

¹⁸ Cf. Bultmann, op. cit., p. 272; Schrenk, op. cit., p. 190. C. K. Barrett, ‘New Testament eschatology. I. Jewish and Pauline eschatology’, SJTh 6 (1953), pp. 136–155 (p. 145, n. 3), says of dikaios, ‘This adjective describes a relationship, not an ethical quality …; if this is not grasped it is impossible to make sense of Paul’s doctrine of justification.’

¹⁹ Morris, op. cit., p. 266; cf. pp. 267, 271. Cf. further J. Buchanan, Justification (London: Banner of Truth, 1961), pp. 240, 243–245; G. E. Ladd, A theology of the New Testament (Grand Rapids: Eerdmans, 1974), pp. 437ff., esp. 443–447.

²⁰ See E. J. Goodspeed, ‘Some Greek notes’, JBL 73 (1954), pp. 84–92 (86–91) where he defends this rendering, earlier presented in Problems of New Testament translation (1954), pp. 143–146, against the criticism of B. M. Metzger in Theology today (January, 1946), p. 562. Goodspeed had a precursor in M. R. Vincent, A critical and exegetical commentary on the epistles to the Philippians and to Philemon (Edinburgh: T. and T. Clark, 1968), pp. 123–128.

²¹ Goodspeed, op. cit., p. 89.

²² Ibid., pp. 88f.

²³ A. B. Davidson, The theology of the Old Testament (Edinburgh: T. and T. Clark, 1961), p. 257, cf. p. 265. Cf. also D. Hill, Greek words and Hebrew meanings (London: Cambridge University Press, 1967), p. 30.

²⁴ Translating as it does the Hebrew zkh (in piel)=‘to make or keep clean, pure’; cf. Brown, Driver and Briggs, s.v.; Schrenk, op. cit., p. 213. It should be noted that even here edikaiōsa does not mean ‘I made upright’.

²⁵ B. M. Metzger, as cited by Goodspeed, op. cit., p. 87.

²⁶ Barrett, Romans, pp. 75f. Barrett’s view has been considered ‘the best solution’ to the ‘long discussions about the meaning of “to justify” ’: E. K. Lee, A study in Romans (London: SPCK, 1962), p. 72.

²⁷ Cf., for a similar description, M. Barth, ‘Rechtfertigung. Versuch einer Auslegung paulinischer Texte im Rahmen des Alten und Neuen Testamentes’, Analecta biblica 42 (1970), pp. 139–209 (139), with reference to Sanday and Headlam, op. cit., p. 36.

²⁸ Thus: Ex. 23:7 kî lö’ ’aṣdîq rās̆ā‘; Dt. 25:1, w^ehiṣdîqû eṯ haṣṣaddîq; Is. 5:23, maṣdîqê rās̆ā‘. Cf. Davidson, op. cit., p. 267: ‘To find right, or in the right, is the meaning of the Hiph., or to justify; or, with slightly different shades of meaning, to declare to be in the right, or show to have right on one’s side’; N. M. Watson, ‘Justification—a new look’, Aust. Bib. Rev. 18 (1970), pp. 31–44 (41).

²⁹ Schrenk, op. cit., p. 204. Cf. G. Bornkamm, Paul (London: Hodder and Stoughton, 1971), p. 138; P. J. Achtemeier, ‘Righteousness in the New Testament’, IDB IV, pp. 91–99 (95b); Ladd, op. cit., p. 445; K. Kertelge, ‘Rechtfertigung’ bei Paulus (Munster: Aschendorff, 1967), pp. 119f. N. M. Watson argues the same point from ‘the creative power of the word in Hebrew thought’, art. cit. (n. 28) (p. 37); he also brings to bear upon the meaning of the verbs in question the OT conception of ‘being as community being’: ‘An act which restores to a man his standing in the community really affects the man himself’ (p. 41).

³⁰ Küng, op. cit., p. 205. Cf. p. 200; and n. 4 above.

³¹ Ibid., p. 203.

³² Ibid., p. 294.

³³ Ibid., p. 204; cf. pp. 206, 210.

³⁴ Ibid., p. 204; cf. p. 225.

³⁵ Ibid., p. 254.

³⁶ Ibid., pp. 294f.

³⁷ In view of the later phrase ‘effective transformation’, is ‘effects’ the word intended here?

³⁸ Küng, op. cit., p. 295 (our italics); cf. p. 297.

³⁹ Ibid., p. 255.

⁴⁰ That the two should be kept distinct is recognized by Küng himself when he says (ibid., p. 292): ‘Justification and sanctification belong together, form a unity in the single event of salvation in Jesus Christ. This does not mean that justification and sanctification may be confused. A theological reduction of these two concepts to one would not correspond to exegetical findings.’ Cf. Buchanan, op. cit., pp. 128, 148, 204f., 401f., 405f., where repeated warning is given against confusing justification and sanctification; F. F. Bruce, The epistle of Paul to the Romans (London: Tyndale Press, 1963, p. 38, n. 2: ‘Failure to observe the distinction leads to confusion in the interpretation of Paul.’

⁴¹ T. W. Manson, On Paul and John, ed. by M. Black (London: SCM Press, 1963), pp. 56ff.

⁴² Ibid., p. 57.

⁴³ Ibid., p. 56.

⁴⁴ Ibid., p. 57. With the first sentence cf. the similar argument of M. R. Vincent (op. cit., p. 127) from Phil. 3:9b: ‘But if the righteousness of faith is legally and forensically imputed, it is of the law.’

⁴⁵ Manson, op. cit., p. 56.

⁴⁶ Ibid.

⁴⁷ Cf. Sanday and Headlam, op. cit., p. 30; Burton, op. cit., p. 473.

⁴⁸ J. Denney, EGT, II, p. 39; cf. Murray, op. cit., pp. 109, 110.

⁴⁹ Burton, op. cit., p. 469; cf. p. 474, under (d).

⁵⁰ Ibid., p. 474.

⁵¹ We may note especially the idea of kauchēsis in Rom. 3:27; 4:2.

⁵² Burton, op. cit., p. 474.

⁵³ Cf. A. Plummer, A critical and exegetical commentary on the epistle of St Paul to the Corinthians(Edinburgh: T. and T. Clark, 1966), p. 91 (on 2 Cor. 3:9): ‘By “righteousness” is meant that which is attributed to man when he is justified. Through faith in Christ man is more than forgiven; his debt is cancelled and he has something placed to his credit.’

⁵⁴ J. Jeremias, The central message of the New Testament (London: SCM Press, 1965), pp. 51–66. Cf. idem, ‘Die Gedankenführung in Röm. 4. Zum paulinischen Glaubens-verständnis’, in Analecta biblica 42 (1970), pp. 51–65 (53, 54).

⁵⁵ Jeremias, Central message, pp. 55, 56.

⁵⁶ Thus, interestingly, whereas Manson would set amnesty as a regal action over against the forensic action of acquittal, Jeremias here regards amnesty as a legal action.

⁵⁷ Jeremias, op. cit., p. 64.

⁵⁸ Ibid., p. 66.

⁵⁹ Schrenk, op. cit., pp. 204f. Cf. H. D. Wendland, Die Mitte der paulinischen Botschaft (Göttingen, 1935), pp. 27f.

⁶⁰ Cf. Schrenk, op. cit., p. 215, n. 18, where he speaks of Paul’s concern in the use of dikaioō as being ‘to clothe the act of grace in legal imagery’. Cf. M. Barth, op. cit., p. 141; p. 178, n. 108; G. Klein, ‘Rechtfertigung im NT’, RGG V, pp. 825–828 (827).

⁶¹ J. A. Ziesler contends that while ‘the verb “justify” is used relationally, often with the forensic meaning “acquit”, … the noun, and the adjective dikaios, have behavioural meanings’ (op. cit., p. 1; cf. pp. 212, 168). I have interacted to some extent with Ziesler’s exegesis in my discussion of various passages in ‘The relationship between righteousness and faith in the thought of Paul, as expressed in the letters to the Galatians and the Romans’ (unpublished PhD thesis, Manchester University, 1975), e.g. vol. II, pp. 191f., n. 190 (on Phil. 3:9).