Bibliotheca Sacra 146 (1989) 132-47. 

          Copyright © 1989 by Dallas Theological Seminary.  Cited with permission.

 

 

 

                  Exodus 21: 22-25 and the

                          Abortion Debate

 

 

                                        Robert N. Congdon

                                               Physician

                                           De Soto, Illinois

 

 

 

 

 

     As a member of the medical community in America, it is with

special shame that this writer views the medically sanctioned, con-

tinuing slaughter of millions of unborn infants.  George F. Will

gently stated that "just as prenatal medicine was beginning to pro-

duce marvelous life-saving and life-enhancing achievements, Sup-

reme Court justices made it the law of the land that the patients for

such medicine have no right to life."1  The awful paradox is that de-

spite tremendous scientific and technological advances improving

the quality of life in the United States, an equally strong advance,

the humanistic ethic has undermined the intrinsic value or sanctity

of all human life.

     Montgomery commented, "While all sins are equal, some sins are

more equal than others."2  God's wrath, he wrote, seems particularly

kindled against certain sinful acts.  Uzzah (2 Sam. 6:6-7) or Ananias

and Sapphira (Acts 5) are examples.  Along with His concern for the

welfare of the family and the institution of marriage and for the

welfare of the Jews, God seems particularly interested in the welfare

of children.  Jesus said, "Let the little children come to me, . . . for the

kingdom of heaven belongs to such as these" (Matt. 19:14, NIV).

 

     Destruction by the horror of being thrown into the sea with a millstone

     around the neck is associated with Babylon in Revelation 18:21 and with

 

     1 George F. Will, "The Case of the Unborn Patient," Newsweek, June 22, 1981, p. 92.

     2 John Warwick Montgomery, "Abortion: Courting Severe Judgment," Christianity

Today, January 25, 1980, p. 54.

                                                          132



Exodus 21 :22-25 and the Abortion Debate                       133

 

     those who do harm to little children in Matthew 18:1-6.  A little child--

     unable to save himself and fully dependent--is, like the Jewish people,

     one of those weak things of this world chosen by God to "confound

     the wise."  Those who harm them do so at their peril, both in time and in

     eternity.3

     Many biologists, geneticists, and physicians agree that biologi-

cal life begins at conception.4  The Scriptures clearly add to that found-

ation by teaching that God places value on unborn life a sacred (see

for instance Exod. 4:11; Job 10:8-12; Ps. 139:13-16; Jer. 1:5; Matt. 1:18;

and Luke 1:39-44).  Waltke summarizes an insightful study of the

Scriptures relating to the nature of fetal life by concluding that "on

both theological and exegetical grounds. . . the body, the life, and

the moral faculty of man originate simultaneously at conception."5

     That the early church fathers recognized this truth is evidenced

in the writings of Tertullian, Jerome, Augustine, Clement of Alexan-

dria, and others.6  The one who studies Old Testament law is sur-

prised, therefore, in light of such evidence to find a paucity of legal

information relating to fetal life.  Kline observed, "The most sig-

ficant thing about abortion legislation in Biblical law is that

there is none."7  This lack of legislation relating to fetal life in He-

brew law is made even more significant by the finding several an-

cient Near Eastern codes of law that deal with the subject.8  For in-

stance a Middle Assyrian law dated between 1450 B.C. and 1250 B.C.

prescribed death by torture in cases of induced abortion.  The text

reads:  "If a woman by her own deed has cast [aborted] that which is

within her womb, and a charge has been brought and proved against

her, they shall impale her and not bury her.  If she dies from casting

that which is in her womb, they shall impale her and not bury her."9

      Does the silence of Old Testament law lead to the conclusion

that God condones the practice of abortion?  This question assumes

 

     3 Ibid.

     4  Statement of "Special Judiciary Committee on Separation of Powers," quoted in

Action Line (CAC newsletter), February 5, 1982, pp. 2-3.

     5 Bruce K. Waltke, "Reflections from the Old Testament on Abortion," Journal of the

Evangelical Theological Society 19 (Winter 1976): 3-13.

     6 John A. Rasmussen, "Abortion: Historical and Biblical Perspectives," Covenant

Theological Quarterly 43 (January 1979): 19-25;  John Ellington, "Miscarriage or

Premature Birth?" Bible Translation 37 (July 1986): 334-37.

      7 Meredith G. Kline, "Lex Talionis and the Human Fetus," Journal of the Evangelical

Theological Society 20 (Summer 1977): 193-201.

    8 H. Wayne House, "Miscarriage or Premature Birth?" Westminster Theological

Journal 41 (1978): 108-23; Bruce K. Waltke, "The Old Testament an Birth Control,"

Christianity Today, November 8, 1968, pp. 99-105.

    9 Cited by Waltke, "The Old Testament and Birth Control," p. 99.



134                 Bibliotheca Sacra / April-June 1989

 

greater significance in light of fact that such an eminent scholar

as Waltke proposed such thinking.10  The "argument from silence

that he proposed has been aptly dealt with by Scott11 and Craw-

ley.12  In light of their comment Waltke was humble enough to re-

tract his earlier conclusions.13

     The silence of Old Testament law referring to feticide does not

mean God is unconcerned about fetus.  Rather, it should lead one

to examine the entire weight of scriptural evidence relating to fetal

status.  Crawley writes that the omission of feticide is "one indica-

tion, among many, of the intense regard felt by the Jewish people for

parenthood and the future of their race."14  Kline states, "It was so

unthinkable that an Israelite woman should desire an abortion that

there was no need to mention offense in the criminal code."15

There is, however, one passage in Old Testament Law that men-

tions the human fetus.  The first of three Old Testament lex talionis

(law of retribution) passages is Exodus 21:22-25:  "And if men struggle

with each other and strike a woman with child so that she has a

miscarriage, yet there is no further injury, he shall surely be fined as

the woman's husband may demand of him; and he shall pay as the

judges decide.  But if there is any further injury, then you shall ap-

point as a penalty life for life, eye for eye, tooth for tooth, hand for

hand, foot for foot, burn for burn, wound for wound, bruise for bruise."

      Differences in interpretation of this law have alternately led to

both acceptance and rejection abortion by evangelicals.

     If it can be established from Exodus 21:22-25 that the unborn fetus is

     qualitatively inferior to fully human life, then the Bible-believing

     Christian must give serious consideration to the contention that there

     are several circumstances that may be greater evils than abortion, such

     as mental disorder in the mother, the probability that the child will be

     born malformed, or the trauma pregnancy resulting from rape.16

   

      This article examines Exodus 21:22-25 from historical, legal,

medical, and textual (linguistic) points of view to seek to reach

conclusion on its meaning, and to answer the question, Does the Old

Testament law condone abortion?

 

     10 Ibid., p. 100.

     11 Graham Scott, "Abortion and the Incarnation," Journal of the Evangelical

Theological Society 17 (Winter 1974):

      12 Encyclopedia of Religion and Ethics (1914), s.v. "Feticide," by A. E. Crawley, 6:

      13 Waltke, "Reflections from the Old Testament on Abortion," p. 3, note.

     14 Encyclopedia of Religion and Ethics, 6:55.

     15 Kline, "Lex Talionis and the Human Fetus," p. 193.

     16 Jack Cottrell, "Abortion and the Law," Christianity Today, March 16, 1973,

p. 7.

 



Exodus 21:22-25 and the Abortion Debate            135

 

      The Context

 

    The Book of the Covenant (Exod. 20:22-23:33) contains regula-

tions concerned with fairness and justice in human relationships.  Its

laws deal specifically with issues such as treatment of slaves, theft

and repayment, sexual mores, crimes of violence, and religious prac-

tice.  While the Ten Commandments (Exod. 20:2-17) summarize the

relationship of the covenant God to His people and relationships

between His people, the Book of the Covenant amplifies this

covenant law.

     The passage in question is found in a series of laws concerned

with cases of criminal negligence.  These are casuistic laws (case

laws) and as such are designed to answer particular legal questions.

Apodictic laws on the other hand are designed to state universal

truths (e.g., "Thou shalt not kill").  Exodus 21:18-19 deals with injury

inflicted during a quarrel.  Verses 20-21 concern punishment of slaves

and manslaughter.  Following the recitation of the lex talionis (vv.

22-25), then, are laws on specific injuries to slaves (vv. 26-27) and in-

juries inflicted by a goring ox (vv. 28-32).  At first glance there seems

little to relate these laws to one another.  But their "casuistic" na-

ture and the placement of the lex talionis in their midst does give

them some affiliation.

     The "law of retribution" is a well-documented legal formula of

ancient Near Eastern legal codes.  It is cited in the Mesopotamian

law codes of Eshnunna (ca. 2000 B.C.), Lipit-Ishtar (ca. 1860 B.C.), and

Hammurabi (1700 B.C.).17  In its literal application, exact retribution

for the injury (or death) incurred was to be applied to the offender.

That the law of talion did not always or even primarily require lit-

eral application, but merely application of its principle, has been

accepted by numerous scholars.18  Fisher notes the following:

     Even in prebiblical times, the principle of monetary substitution

     (payment of claims and damages) was gradually replacing literal,

     physical retribution. The code of Eshnunna, for example, states that "If

     a man bites the nose of another man and severs it, he shall pay one

     mina of silver.  For an eye, one mina; for a tooth one-half mina; for a

     slap in the face ten shekels of silver."19

     Examination of the two other biblical lex talionis texts concurs

with the idea that literal interpretation is not mandated. In

 

      17 Eugene Fisher, "Lex Talionis in the Bible and Rabbinic Tradition," Journal of Ecu-

menical Studies (Summer 1982): 582-87.

     18 Floyd E. Schneider, "Penology in the Mosaic Law" (ThM thesis, Western Conser-

vative Baptist Seminary, May 1978), pp. 7-12; Kline, "Lex Talionis and the Human Fe-

tus," pp. 196-97; Fisher, "Lex Talionis in the Bible and Rabbinic Tradition," pp. 584-85.

      19 Fisher, "Lex Talionis in the Bible and Rabbinic Tradition," pp. 584-85.



136      Bibliotheca Sacra / April-Jun     1989

 

Leviticus 24:18 the "life-for-life” principle is applied to the situa-

tion in which an animal's life is taken, and this is interpreted three

verses later by the statement that "the one who kills an animal

shall make it good."

     Likewise in Deuteronomy 19:5-21, which speaks of judging

false witness, there is "not a simple literal equivalence between the

terms of the talion penalty clause and all the variety of cases

which a false witness might figure."20

     The application of the law talion in Exodus 21 is similarly

nonliteral.  The kinds of injuries listed in the talion formula (e.g., a

burn) are not ones likely to occur in a situation where two men strug-

gle with each other and inadvertently strike a pregnant woman

Furthermore the immediate context refers to the situation in which

men quarrel and injury is inflicted (vv. 18-19).  Instead of the ex-

pected "wound for wound" formula, monetary compensation is man-

dated.  Similarly the passage that follows (vv. 26-27) mandates

decidedly nontalionic judgment:  a slave's freedom for traumatic loss

of eye or tooth.

     Clearly then the lex talionis formula provides for exact justice,

not for exact retribution.  The punishment must be commensurate with

the crime, neither too excessive nor too lenient.  One might postulate

on this basis that the penalty "life for life" might be amended in the case of

some cases as well.  Certainly the "ransom" allowed in the case of

the negligent owner of a goring ox (v. 30) would seem at first glance to

fit such a proposition.  However, owner's negligence is taken into

account here.  Keil and Delitzsch note, "As this guilt, however, had

not been incurred through an intentional crime, but had arisen simply

from carelessness, he was allowed to redeem his forfeited life by

payment of expiation money."21  And the homicide was not commit-

ted personally, with murderous intent, and therefore fell outside the

restriction of Numbers 35:31-32, which allowed no ransom in such

situation.

     In the case of premeditated murder, even the altar of Yahweh

could not protect the offender fro the death penalty (Exod. 21:14).

The application of lex talionis in Leviticus 24:17-21 makes it clear

that while "life for life" may only require compensation if the

death of an animal is involved, it most certainly requires capital

punishment if a man is killed.  Likewise the "cities of refuge" (Num.

35:9-21) were for those who had committed unintentional man-

 

     20 Kline, "Lex Talionis and the Human Fetus," p. 197.

     21 C. F. Keil and F. Delitzsch, "Exodus," in The Pentateuch, 3 vols., trans. James Mar-

tin, Commentary on the Old Testament (Grand Rapids: Wm. B. Eerdmans Publishing

Co., 1949), 2:135.

 



Exodus 21:22-25 and the Abortion Debate            137

 

slaughter.  One guilty of premeditated murder had absolutely no

recourse.  "You shall not take ransom for the life of a murderer who is

guilty of death, but he shall surely be put to death" (Num. 35:31).  If

the guilty one fled to a city of refuge, the Law stated that "the el-

ders of his city shall send and take him from there and deliver him

into the hand of the avenger of blood, that he may die" (Deut. 19:12).

     Every crime except for premeditated murder could be remedied

by restitution of some sort.  Even manslaughter could be remedied

this way, if the motives of the perpetrator were not culpable.

     As seen, lex talionis in Leviticus 24 applies the "life-for-life"

formula to the situation of intentional manslaughter.  Its application

in the Deuteronomy 19:21 context is likewise to a situation where in-

tentional manslaughter occurs (vv. 11-13) or is intended by false

testimony (v. 19).  While many have ascribed the lex talionis pas-

age in question (Exod. 21) to an event of unpremeditated injury,22 it

would seem evident from the biblical context of lex talionis usages

that an intentional event is being judged.  A study of talionic law in

Babylonian and Islamic contexts similarly reveals its application

only in cases of intentional homicide and injury.23

    In an excellent discussion of the intentional nature of this crime,

Layton analyzes the use of the Hebrew verb hcAnA in Exodus 21:22.24

The use of  hcAnA implies a premeditated, physical struggle.  This clari-

fes the enigma of a talionic punishment for the mortal injury in this

text.  Only in light of intentionality does the use of lex talionis make

sense.  Only in such a light can one understand the lack of any provi-

ion for the perpetrator's protection in a city of refuge.

 

The Case

    The law in Exodus 21:22-25 is formulated in a twice-repeated "if

. . . then" fashion.  The "if" part of each conditional statement, re-

ferred to as the protasis, speaks of the legal situation.  The "then"

part, known as the apodosis, speaks of the legal consequence.25  The

difference between the first statement (v. 22) and the second state-

ment (vv. 23-25) revolves around the word  NOsxA, translated "injury."

 

     22 John M. Frame, "Abortion from a Biblical Perspective," in Thou Shalt Not Kill, ed.

Richard L. Ganz (New Rochelle, NY: Arlington House, 1978), p. 52; J. Carl Laney,

"The Abortion Epidemic: America's Silent Holocaust," Bibliotheca Sacra 139

October-December 1982): 348; R. Alan Cole, Exodus (Downers Grove, IL: InterVarsity

ress, 1973), p.169.

     23 Scott Layton, "An Exegesis of Exodus 21:22-25 in the Light of Ancient Near

Eastern Law" (ThM thesis, Dallas Theological Seminary, 1979), p. 46.

      24 Ibid., pp. 12-13.

      25 Kline, "Lex Talionis and the Human Fetus," p. 193.

 



138     Bibliotheca Sacra / April-June 1989

 

The first statement speaks to the situation where there is no NOsxA and

a fine is mandated.  The second statement speaks to a situation in-

volving NOsxA and the lex talionis is applied.

      The protasis in verse 22 sets forth the situation where men are

fighting (most likely two men) with intent to cause injury.  Unfortu-

nately for all involved, a pregnant woman gets in the way of a blow

and is struck. Whether she is an innocent bystander or the wife of

one of the assailants is not clear from the text and is inconsequential

to the outcome.  What is of significance is what happens to the

woman.  After she is struck, "her children go out" (hAyd,lAy;  Uxc;yAv;).  Be-

cause the understanding of this phrase is critical to a correct under-

standing of this passage, it bears close evaluation.  Is this a case of

premature live birth or of miscarriage?

     The term dl,y, is the common Hebrew word for child or offspring.

Why the plural form is used here is unclear.  Keil and Delitzsch

suggest that it is used in an indefinite sense, to indicate that there

might be more than one child in the mother's womb.26   Kline proposes

that the use of the plural is "peculiarly appropriate to an aborted

fetus, especially at an earlier, more amorphous embryonic stage."27

House suggests that it is employed grammatically to indicate

"natural products in an unnatural condition."28

      While  dl,uy, elsewhere always means "living child" or one capa-

ble of living outside the womb (Gen. 44:20; Isa. 9:6), the adopting of

the plural in this case is a significant modifier indicating the unnat-

ural state of affairs.  But that the circumstances were unnatural does

not adequately answer the controversial question of whether the

baby "came out" alive or dead.

     Many recent interpreters have concluded that the use of the verb

xcAyA ("to go or come out") indicates nothing other than the birth of a

living child.29  This conclusion is based on two key points:  the Old

Testament usage of xcAyA, and the availability of a specific term for

miscarriage which was not employed.  As for the latter, the Hebrew

word for miscarriage is lkawA.  This term is used frequently throughout

the Old Testament (Gen. 31:38; Exod. 23:26; Hos. 9:14; 2 Kings 2:19;

etc.) referring to the miscarriages of women, of animals, and of non-

productive land.  As for xcAyA it is utilized in reference to the normal

births of Jacob and Esau (Gen. 25:25-26), Perez and Zerah (Gen. 38:27-

30), and Jeremiah (Jer. 1:5; 20:18).  When Job lamented about his own

 

     26 Keil and Delitzsch, "Exodus," p. 135.

     27 Kline, "Lex Talionis and the Human Fetus," p. 193.

     28 House, "Miscarriage or Premature Birth?" p. 114.

     29 Ellington, "Miscarriage or Premature Birth?" p. 337.


Exodus 21:22-25 and the Abortion Debate            139

 

birth, he used this word (Job 3:11; 10:18).  It has been purported that

in every case where  xcAyA is used in the context of childbirth it refers to

a live birth except in Numbers 12:12.  This verse is clearly speaking

of a stillbirth, but Cottrell is correct in noting that it is not the verb

that communicates the concept of death.30  In this verse the subject is

not dl,y,, "child," but tme, "something dead."31

     While xcAyA normally refers to ordinary childbirth, it is a neutral

term and may denote anything that "comes out" of the mother's

womb.32  In Numbers 12:12 it refers to a nonviable fetus.  In Job 3:11 it

is used to describe neither an ordinary delivery nor a stillbirth, but a

difficult delivery with resulting perinatal death of the infant,33 an

all-too-common occurrence even today in areas that have inadequate

obstetric care.

     The word xcAyA as used in Exodus 21:22 may refer to other than a

live birth.  Kline concludes that "it is not demonstrable either that

this language in itself must be understood with reference to a miscar-

riage or that it cannot be so understood."34  He astutely notes that

even those who allege that this must refer to a live birth take it to

refer to a miscarriage when they come to the second conditional

statement (v. 23).  For here they relate the (possibly) fatal injury to

both mother and child.35  (To maintain that dl,y, must indicate a liv-

ing child proves difficult at this same point, for a deadly injury to

both would obviously result in a miscarriage or stillbirth.)  This

writer feels that the weight of evidence favors an interpretation of

xcAyA in Exodus 21:22 as "miscarriage" and not "live birth."  This con-

clusion is based on the following textual, historical, and ancient

Near Eastern legal evidence and on medical evidence.

 

The Evidence

      First, as already noted, the textual evidence doe not mandate

an interpretation of "live birth."  In fact the Mishnah in its com-

mentary on this Exodus 21 passage (Baba Kamma 5:4) uses this pre-

cise phrase "unequivocally in the sense of miscarriage.36

 

     30 Cottrell, "Abortion and the Mosaic Law," p. 8.

     31 Ellington, "Miscarriage or Premature Birth?" p. 336.

     32 Layton, "An Exegesis of Exodus 21:22-25 in the Light of Ancient Near Eastern

Law," p. 20.

     33 Ibid., p. 38, n. 35.

     34 Kline, "Lex Talionis and the Human Fetus," p. 198.

     35 Ibid.

     36 Layton, "An Exegesis of Exodus 21:22-25 in the Light of Ancient Near Eastern

Law," p.22.



140     Bibliotheca Sacra / April-June 1989

 

     Second, the historical exegesis of the passage has universally

given it the meaning of miscarriage.  Waltke quite conclusively

makes this point, citing a long list of ancient scholars.37

     Third, a comparison with five ancient Near Eastern law codes in

similar case law formulations reveal that all of them refer to mis-

carriage and not to premature birth.38  As Layton comments,

      These laws cannot be ignored, for virtually all Old Testament exegetes

      acknowledge the value of them in illuminating the meaning of the legal

      portions of the text.  It would seem incredible for Exodus 21:22 to deal,

      with premature birth while the other five legal collections deal with

      miscarriage.39

 

     Fourth, of particular interest to to this writer is the medical data

that speaks to the viability of infants delivered prematurely after a

traumatic incident.

     Studies show that trauma of all types occurs in five to ten per-

cent of all pregnancies.40  In the early gestational period the uterus is,

protected by the bones of the mother's pelvis and is fairly immune to

trauma.  In the second and third trimesters of pregnancy the enlarg-

ing uterus becomes more and more vulnerable.  For this reason pene-

trating abdominal wounds have a high fetal mortality as pregnancy

progresses.  The situation described in Exodus, however, appears to

indicate blunt injury and not the penetrating variety (a stab wound is

not inferred).

     Contrary to popular opinion, blunt abdominal trauma that is not

severe usually causes no problem to the fetus, well-protected as it is

within the uterus and amniotic "shock-absorber."41  Well over two-

thirds of blunt trauma in pregnancy in the Western world happens in

the course of motor vehicle accidents or physical assault.  And even

in the high-energy impact of the former, "despite its prominence. . .

the uterus and contents stay intact most of the time."42

     Thus it seems fair to assume that the blow delivered in the bib-

lical case was significant.  Kline builds a convincing argument for

 

      37 Bruce K. Waltke, "Letter to the Editor," Christianity Today, January 3, 1969, p.

302.

     38 Layton, "An Exegesis of Exodus 21:22-25 in the Light of Ancient Near Eastern

Law," p. 18.

     39 Ibid.

     40 Michael Katz, "Maternal Trauma during Pregnancy," in Maternal-Fetal Medicine,

ed. Robert K. Creasy and Robert Reshick (Philadelphia: W. B. Saunders, 1984), p. 773.

     41 J. Pritchard, P. MacDonald, and N. Gant, "Injuries and Malformations of the

Fetus, and Newborn Infant," in Williams Obstetrics, 17th ed. (Norwalk, CT: Appleton, Cen-

tury, Crofts, 1985), p. 797.

     42 Katz, "Maternal Trauma during Pregnancy," p. 777.



Exodus 21:22-25 and the Abortion Debate            141

 

such an understanding of the verb JganA ("to strike") based on its use in

other scriptural texts.43

     The most common reason for fetal demise in such cases is the

death of the mother with secondary death of the unborn child.44

Kline's suggestion that the mother dies from the blow but the baby

lives45 is medically nonsensical: a cesarean section might save the

baby's life if it were performed within five minutes of the mother's

death.  If the mother survives and the child is born (in the bibli-

cal case), this raises the question of the status of the baby which

"comes out" prematurely.

     First, it is important to note that injury to the fetus in utero may

be direct or indirect.  Direct injury is rare, mainly occurring late in

pregnancy when the head is deep in the pelvis and major trauma

causes fetal skull fracture.  A recent review of the obstetric literature