Jim Congdon, Senior Pastor, Topeka Bible Church, Kansas, usa

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Believers’ relation to the Law: not obligation, but fulfillment

Jim Congdon, Senior Pastor, Topeka Bible Church, Kansas, USA

Torah-observance has long been accepted as permissible for Jews who have come to faith in Yeshua, and even for Gentile believers as well.1 But recently some messianic leaders have asserted that Torah-centered living is normative for messianic Jewish congregations.2

In an atmosphere of requirement, it is helpful to remind ourselves that God’s people are no longer under obligation to the Law of Moses. We will briefly pursue two lines of evidence linked by the enigmatic word “fulfill.” Jesus said that He came to “fulfill” the Law; Paul wrote that believers “fulfill” the Law. We will argue that both statements indicate that the believer is free from the Law.3

1. Jesus “fulfilled” the Law by inaugurating a new age

To summarize: Jesus teaches in Matthew 5 that He is the new and living Torah – the realization of the Old Testament, the culmination of the Law of Moses. Paul affirms the same truth in Romans 10:4.

a. Matthew 5:17-48

Matthew 5:17-20 is the critical text for the question of the abiding force of the Mosaic Law in the life of the believer. It is often summoned as the expert witness to prove the Law-obligation view, but the witness itself destroys the case, for it says “too much” for that view, whether offered in its Reformed theological form or its Jewish Torah-observant form.

Matthew 5:17-18 says “too much” for the traditional Reformed view which would neatly resolve this crux interpretum by dividing the Law into “abiding” (moral law) and “abrogated” (civil, ceremonial) parts-­for Jesus is declaring that the entire Mosaic Law remains in force. This idea that Jesus was referring only to the moral laws (especially the Decalogue) within the Torah is unable to handle the all-embracing sweep of Jesus’ next words (v. 18), which gather “every iota and dot” of the Law into that which, he declares, will not pass away “until all is accomplished.”4

Similarly Matthew 5:18 says too much for the messianic Jewish view that compliments itself on correctly noting that the Law is an indivisible unit – for confronted with the actual 613 laws themselves, Torah-observant believers are compelled to ‘take the absolute value’ of each, removing multiple iotas here, dots there--of sacrifices, purifications, and penalties for disobedience--for much of the Law requires Temple, priesthood, and presence in the Land.5 Westerholm is right to ask: “How can Christians be said to ‘fulfill’ the law when a significant number of its commands are disregarded?”6 Once again, this is a reductionist interpretation of

v. 18 which fails to honor the inclusive sweep of Jesus’ words.

Instead, Jesus must be saying that the Mosaic Law in toto remains in force. But how can this be, since we are told that He abolished the food laws (Mark 7:19), and that the sacrificial system is abolished (Hebrews 8:13; 10:1-18)? The explanation must be “eschatological”: Jesus is claiming that he is the climactic figure of history, and that the Law and Prophets remain in force in Himself. He has come to inaugurate a new age in salvation history – not an age in which the old age is abolished, but the age to which it pointed and in which it is fully realized.7 One may compare how a graduate student looks back on his undergraduate years of schooling. Are those university days now abolished? Never! They will always be cherished, yet only as the preparation of the advanced study to which they intentionally pointed.

Two textual witnesses support this exegesis: the verb “fulfill” (v. 18) and the six “words” that follow (vv. 21-48). Our Lord’s choice of verb (pleroo, “fufill”) is critical: “The antithesis is not between ‘abolish’ and ‘keep’ but between ‘abolish’ and ‘fulfill.’”8 While many interpretations have been suggested, the best is the one that sees it as part of the promise-fulfill­ment theology of Matthew which pictures the entire OT as promising and anticipating Jesus.9 Indeed, it mirrors Jesus’ statement a few chapters later that “The Law and Prophets prophesied until John” (11:13).10 It is in Christ that all that the Law anticipated is about to be “accomplished”

(v. 18 – in His teaching, his ministry, and especially in his death and resurrection.

“Jesus does not conceive of his life and ministry in terms of opposition to the Old Testament, but in terms of bringing to fruition that toward which it points. Thus, the Law and the Prophets, far from being abolished, find their valid continuity in terms of their outworking in Jesus. The detailed prescriptions of the Old Testament may well be superseded, because what­ever is prophetic must be in some sense provisional. But whatever is prophetic likewise discovers its legitimate continuity in the happy arrival of that toward which it has pointed.”11

This interpretation of Matthew 5:17-18 is also confirmed by the six “words” which follow (vv. 21-48), in which Jesus sets Himself up as the new Torah-giver. Those who view the Law as still binding argue that Jesus is simply giving the “deeper, original meaning” of the ancient laws here, but while this explanation will do for His third word (on adultery), it will not suffice for the others. Others respond that Jesus is “expanding the meaning” of the old laws, but while that will do for his first and second words (on murder and adultery), it will not suffice for the others. Instead, the point which Matthew wants us to see, by repetition, is that Jesus is the new Law­giver, who alone has the authority to say “you have heard that it was said…but I say unto you.”12

The Transfiguration story (17:1-8; cf. Mark 9:2-8; Luke 9:28-36) is probably meant to illustrate this replacement theme. Moses had gone up into a high mountain on the seventh day (Ex 24:16); “after six days” Jesus goes up into a high mountain. Moses had been accompanied by Aaron and a pair of brother priests, Nadab and Abihu; Jesus was accompanied by Peter and the brothers James and John. As Moses had entered the cloud and divine light with the result that his face shone, so Jesus shone with heaven’s light; and before Him appeared Moses and Elijah, the only OT saints to receive a revelation on “the mountain.” As tents had been part of the ritual of Moses receiving revelation (Ex 33), so Peter suggests that tents be erected for the three recipients of revela­tion. But at this juncture there is a sharp discontinuity meant to catch our attention. At Sinai God had revealed himself with “I am Yahweh,” and then given the Ten Words to Moses; but here and now, God introduces his son, “This is my beloved Son,” and then says, “Listen to him.” The gospel writer could not present it more clearly: Jesus has become the revealed Word. The old Torah has given way to One who himself is the new and living Torah.

Where, then, is the code of conduct for “life in the kingdom” here and now? According to vv. 19-20, our ethic is found in “these commands” of Jesus, which assume and advance the Old Testament law, and last forever (cf. 24:35; 28:20).13 The Law and Prophets no longer govern God’s people directly – only Christ does that – but provide principles “for teaching, rebuking, correcting, and training in righteousness” (2 Tim 3:16), when filtered through the lens of Jesus’ works and words. This exegesis explains the relatively few number of times that Jesus cites the Law to support His demands, as well as statements such as “the Son of Man is Lord even of the Sabbath” (Mark 2:28), and the fact that Jesus leaves his disciples with the command to take His teaching to the world (Matt 28:20).

b. Romans 10:4

In his most famous statement on the Law, Paul affirms that Jesus is the goal and end of the law. He writes: “Christ is the end of the Law so that there may be righteousness for everyone who believes” (Rom 10:4). The Apostle seems to be declaring a “full stop” to the law of Moses, but both of the words in the phrase telos nomou are debated, and the study leads us to the same conclusion as in Matthew 5.

Some proponents of Law-obligation deny that Romans 10:4 refers to the Law at all. Instead, they say, Paul declares that Christ is the end of legalism, the Law’s misuse as a way of salvation. But this escape route is closed, for Paul nowhere else uses nomos to mean legalism, while its normal use is the Mosaic law.14

Most proponents of Law-obligation instead note that telos can take the meaning “goal” rather than “end,” and argue that this is what Paul means here.15 The Law could then remain in full force for believers today. These two options are sometimes presented as stark contrasts: Either Christ has terminated the Law, or the Law remains in full force.

We do not need to choose between these two opposite poles, however, and should not do so here. In this context Paul seems to be saying that Christ is both “goal” and “end”: Christ is the “goal” of the Law, in the sense that the Law has always looked forward to him (10:2-3). But He is also its “end” in connection with righteous­ness, because through Him comes faith as the new means to righteousness (9:30-32; 10:4b).16 By telos, then, he means that he is the Law’s “point of culmination.”17 (p. 207, Moo, Continuity and Discontinuity)

Therefore Paul is saying the same thing about Christ that Christ said about himself -He is the culmination of the Law. Its permanence is guaranteed, yet not in its own continued existence but rather in its fulfillment in his teachings and in the new age of life in the Spirit.

2. Believers “fulfill” the Law, even while they are free from it

To summarize: Paul is adamant that believers are no longer subject to the Law of Moses; yet he also expects that believers must comply with the moral demands of the Law. This conundrum is resolved by the apostle himself, who declares that believers comply with the Law’s demands not by “doing” the Law but by “fulfilling” it, when they walk by the Spirit in love.

a. Believers are free from the Law

A heavy burden of proof rests those who would teach Law-obligation today, for Paul declares unequivocally that believers are no longer subject to the Law: they have “died to the law” (Rom 7:6; Gal 2:19); they have been “set free” from the law (Rom 7:6); they are no longer “under” the law (Rom 6:14-15); they have been “redeemed” from the law (Gal 4:5).

As a Pharisee, Paul had understood the Torah to be the highest revelation of the will of God to man. But in his vision of the risen Jesus on the road to Damascus, Paul recognized in him a fuller, eschatological revelation of God. In other words, Christ, the bearer of the image of the invisible God, has superseded the Torah as the revelation of God and of his will for mankind (2 Cor 4:4-6). The age of the Law has been replaced by the age of Christ (Gal 3:19-4:5). And so while the Jews to whom he preaches are under obligation to observe the Law’s demands, Paul says that he is not (1 Cor 9:20).

Finding scant support in Paul, those who teach Law-obligation often sift the early church narratives of Acts for help. Finding Torah-observance by Peter, James, and even Paul himself (!), they commandeer it as ground for the doctrine that believers--at least the Jewish ones-­are still subject to the Law.18 But early church practices will not bear this heavy theological weight. Thoughtful readers of Luke/Acts will remind themselves that: (1) the early church of the Gospels and Acts occupied a kind of salvation-historical transitional phase as the Old Covenant was still in effect even as the New was in the process of inauguration; (2) the Jewish Christian therefore belonged to two communities – to the new covenant people as a believer, but to the Old Testament civil and social legislation as a Jew; (3) according to Luke, the early church merely rolled on in the well-worn grooves of Jewish piety, only working out the full implications of the new covenant gradually;

(4) Stephen and other early Christian were accused by antagonistic Judaism of challenging the centrality of the Law and the temple for God’s people, and they did not deny it; (5) the gospel was preached beyond the boundaries of Judaism, and those who believed were admitted to the church without becoming proselytes; (6) Peter opposes nomism in Acts 15:10-11 with a programmatic statement which dismisses the imposition of Torah-observance as “a yoke that neither we nor our fathers have been able to bear”; (7) the Sabbath, holiday, and purity practices of the apostles are therefore best seen as arising not from Law-obligation theology, but from one or more of the following factors: habit, religious conservatism, social pressure, avoidance of persecution, and missionary policy (“to the Jew I become as a Jew,” 1 Cor 9:20).19 We conclude that the continuing first century practice of the Law by believing Jews falls into the category of liberty, not law. The Willowbank Declaration agrees: “We affirm that Jewish people who come to faith in Messiah have liberty before God to observe or not to observe traditional Jewish customs and ceremonies that are consistent with the Christian Scriptures.”20

Paul’s certainty that believers are free from the Law would be perfectly straightforward were it not also clear that he expects believers to comply with its moral demands (Rom 8:4; 13:8-10; Gal 5:14). How is this resolved?

b. Believers who walk by the Spirit in love automatically “fulfill” the Law

Paul says that believers must “fulfill” the law (Rom 8:4; 13:8-10; Gal 5:14). But nowhere does he require that believers “do” the Law. This distinction is more than semantic. To “do” the Law, the believer would need to perform its individual and specific commands (Gal 5:3). To “fulfill” the law – described by Paul as walking by the Spirit in love--does not require performance of the specific legal requirements. Yet, says Paul, it completely satisfies what is required. But how is it possible to “fulfill” the Law without actually “doing” the Law?

Consider an illustration. A foreign exchange student from Greece enrolls in Introductory Greek at a school in the States. The instructor soon realizes that the student more than adequately “fulfills” the requirements of the course, and releases her from “doing” the assignments.21 According to Paul, the Christian who walks by the Holy Spirit in love bears a similar relationship to the Law. He “fulfills” its demands without ever actually “doing” its specific requirements.

Romans 7:5-6 is definitive.22 Believers have been set free from the Law (the “moral” law is included, v. 7), so that they now serve God in the new way of the Spirit rather than in the old way of the written code.23 Paradoxically, the results of the new way – fulfillment of the Law, service in love (Rom 8:4; Gal 5:13) – are better than the results of the old way – sinful passions, disobedience, and death (Rom 7:5; 2 Cor 3:6; Gal 3:19).

To summarize: Both Jesus and the believer are said to “fulfill” the Law. In neither instance is “doing” the Law in view; yet in both instances, the demands of the Law are fully satisfied. In the case of Jesus, the whole Law finds fulfillment – complete satisfaction and permanent validity--in his person and words. In the case of Jesus’ followers, the whole Law finds fulfillment – complete satisfaction of all requirements – in their submission to the person of words of Christ.

Christ, then, is the heart of New Testament ethics. He is everything that Judaism has claimed for Torah, and much more. He, rather than the Law, is the Wisdom of God, the Bread of Life, the Word, the Instrument of God’s creation, the Light of the world, the Way, the Truth, the Life, the Glory, the Shepherd, and the Teacher. God speaks: “This is my beloved son; listen to him.”

Jim Congdon jcongdon@topekabiblechurch.org


  1. That Gentiles often greatly outnumber Jews in their synagogues poses an added theological difficulty for messianic rabbis who preach law-obligation; David Klinghoffer, in a recent issue of the Jewish women’s magazine Hadassah, names a messianic rabbi in Seattle who admitted to him that only about 2% of his Beit Tikvah congregation of 200 are Jewish-born (Hadassah, May 2007; vol. 88, no. 9).

  2. This is the argument of Mark Kinzer,

Post-Missionary Messianic Judaism, Brazos, 2005. The use of Judaism is deliberate by Kinzer, for whom Jews in rabbinic Judaism rest under God’s redemptive favor and may be saved through Jesus, even if they do not believe in him (p. 25).

3. This does not mean we are lawless, of course. To broadly summarize, using distinctions as old as Thomas Aquinas: (1) Everyone is under the law of Nature; (2) No one is under the Law of Moses; (3) Believers are under the law of Christ. See

J. Budziszhewski, Written on the Heart: A Case for Natural Law (Downers Grove, IL: InterVarsity Press, 1997. When referring to the Law of Moses in this article, we capitalize “law,” to distinguish the Law of Moses from the laws of God, nature, and Christ.

  1. Paul is unaware of the threefold division of the Law upon which much of the modern argument for the continuing validity of the Law is based. This division would have been repugnant to the Jews, for whom all 613 commands were moral, and it is spurned by them to this day. While general comparisons were drawn in biblical times between “weightier and lighter matters of the law” (Matt 23:23), sharp lines were not drawn until post-biblical times. When the NT refers to “the law,” it generally means the entire Mosaic corpus of law.

  2. “For the most part, the emphasis is on holy days, Sabbaths, and festivals, with perhaps some attention given to other parts of the Law. In essence, these are not so much Torah-observant as festival-observant groups.” Rich Robinson, Havurah, winter 2005, vol. 8:4, p. 2.

  3. Stephen Westerholm, Israel’s Law and the Church’s Faith: Paul and His Recent Interpreters (Grand Rapids: Eerdmans, 1988), p. 202, citing E. P. Sanders in support. He adds on p. 221 that “it was Paul who realized that when the sanctions of the law have been removed, its demands have no force.”

  4. The first thorough delineation of this “salvation-history” interpretation is usually attributed to Robert Banks, Jesus and the

Law in the Synoptic Tradition, SNTSMS 28 (Cambridge: CUP, 1975).

  1. D. A. Carson, “Matthew,” in The Expositor’s Bible Commentary, vol. 8 (Grand Rapids: Zondervan, 1984), 243.

  2. Douglas J. Moo, “The Law of Christ as the Fulfillment of the Law of Moses: A Modified Lutheran View,” in Five Views on Law and Gospel, ed. Stanley N. Gundry (Grand Rapids: Zondervan, 1996), pp. 347-353.

  3. It may be helpful to observe that for Matthew, Jesus is here thinking of the Hebrew Scriptures, and especially the Torah, not as a “code” or even primarily as an “ethic” but as a “promise”--a promise which reaches forward to its fulfillment in himself, the new and living Torah. See Darrell L. Bock, Luke 1:1-9:50 (Grand Rapids: Baker, 1994), p. 39, who draws these distinctions in the Third Gospel.

  4. D. A. Carson, The Sermon on the Mount: An Evangelical Exposition of Matthew 5-7 (Grand Rapids: Baker, 1978),

p. 37.

  1. Moo, Five Views, 347-350.

  2. By “these commands” Jesus must not be referring not to Old Testament law per se, to which the Pharisees and scribes who will not enter the kingdom (v. 20) adhere, but to his own words in their fulfillment of the law (vv. 18-19), words will never pass away (Matt 24:35; 28:20). See

A. T. Lincoln, “Sabbath, Rest, and Eschatology in the New Testament,” in

From Sabbath to Lord’s Day: A Biblical, Historical, and Theological Investigation

(Grand Rapids: Zondervan), 1982, p. 219,

n. 82; followed by D. A. Carson, From Sabbath to Lord’s Day, p. 78.

  1. Douglas J. Moo, “’Law,’ ‘Works of the Law,’ and Legalism in Paul,” Westminster Theological Journal 45 (1983) 73-100.

  2. C. E. B. Cranfield, A Critical and Exegetical Commentary on the Epistle to the Romans, 2 vols. [Edinburgh: T. & T. Clark, 1975, 1979], 2:516-19; Daniel P. Fuller, Gospel/Law: Contrast or Continuum? (Grand Rapids: Eerdmans, 1980), 82-85; Frank Thielman, Paul and

the Law: A Contextual Approach (Downers Grove, IL: InterVarsity Press, 1994), 207.

16. Bauer, Arndt, Gingrich, A Greek-English Lexicon of the New Testament and Other Early Christian Literature (Chicago: University of Chicago Press, 1957), 818­


  1. Douglas J. Moo, “The Law of Moses or the Law of Christ,” in Continuity and Discontinuity: Perspectives on the Relationship Between the Old and New Testaments (Westchester, IL: Crossway Books), 1988, p. 207.

  2. Kinzer, Post-Missionary Messianic Judaism, is the most recent example of resting one’s case for abiding Torah-observance on the narratives of Acts, rather than the teaching of Jesus and Paul.

  3. Max M. B. Turner, “The Sabbath, Sun­day, and the Law in Luke/Acts,” in From Sabbath to Lord’s Day, 121-26; Arnold Fruchtenbaum, Israelology: The Missing Link in Systematic Theology, 2nd ed. (Tustin, CA: Ariel Ministries, 1994), 648.

  4. In a nice turn of phrase, the position statement of Jews for Jesus “affirms Jewish believers who, for the sake of honoring our heritage and developing a Jewish testimony, choose to give up some of what grace allows to conform to dietary standards and various other Jewish practices.” (italics mine)

  5. Westerholm, Israel’s Law and the Church’s Faith, p. 203, uses the illustration of a concert pianist who enrolls in an undergraduate music course. The argument here is indebted to Westerholm, ch. 10.

  6. This is the text that, Mosaic law scholar Frank Thielman confesses, finally “converted” him to the view that “Paul considered the Mosaic covenant obsolete”; see Paul and the Law: A Contextual Approach (Downers Grove, IL: InterVarsity Press, 1994), 242.

Space does not permit discussion of the essentials of the new covenant ethic: the central command of love, the law of Christ, walking by the Spirit.

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