Westminster Theological Journal 55 (1993) 113-35.

        Copyright © 1993 by Westminster Theological Seminary, cited with permission.  





                                       THOMAS R. SCHREINER


                                                  I. Introduction


TWO difficult verses for understanding Paul's view of the law are Rom

10:4-5. Rom 10:4, for example, has often been used to posit an absolute

discontinuity between law and gospel since Paul says here that "Christ is

the end [te<loj] of the law." Others, however, claim that to read such

discontinuity into the verse is unwarranted, and they argue that Paul is

asserting that "Christ is the goal of the law." In this latter view, faith in

Christ is the goal to which the law points, and there is a fundamental

harmony between the gospel and the OT law. Although Rom 10:5 has not

been as significant in the history of interpretation as Rom 10:4, the meaning

of this verse has been the subject of increasing debate in recent years. Since

these two verses are important for determining Paul's stance toward the OT

law, it is my goal to examine various interpretations of Rom 10:4-5 and to

defend the interpretation which is the most credible.


                      II. Christ is the End of the Law: Rom 10:4


            The interpretation of te<loj ga>r no<mou Xristo<j is a well-known battle-

ground in Pauline studies,1 and we cannot in this article examine in suf-

ficient detail a verse which has been of such controversy. Nevertheless,

various interpretations of the verse will be described and critiqued,2 and I

will attempt to defend my own view.


1. The Law Is Abolished

            One of the dominant views in NT scholarship, especially in Lutheran

circles, is that Christ is the end of the law in the sense that the OT law is


1 For the history of interpretation see R. Badenas, Christ the End of the Law: Romans 10:4 in

Pauline Perspective (JSNTSup 10; Sheffield: JSOT, 1985) 7-37; J. A. Nestingen, Christ the
End of the Law: Romans 10:4 as an Historical Exegetical-Theological Problem
(Ph.D. dissertation,

University of Toronto, 1984).

2 It should be noted that some of the scholars fit into more than one of the categories listed

below, indicating that there is some fluidity between some of the interpretations. The most

notable contrast is between those who translate te<loj as "goal" and those who translate it

as "end."





now abolished for the believer.3 Christians are no longer under the law (cf.

Rom 6:14-15; Gal 5:18), and thus the Mosaic law is not binding for the

believer. Even the moral law of the OT is abolished since the whole law has

passed away (cf. Gal 5:3), and no distinctions between various parts of the

law can be supported either from Jewish literature or Paul.

            This interpretation is difficult to tackle in a brief space because it intro-

duces the thorny issue of how the Testaments relate to one another. The

major defect of this view is that other statements in Romans (2:26; 8:4;

13:8-10; cf. also 1 Cor 7:19; Gal 5:14) indicate that Paul expected believers

to obey the moral norms of the Mosaic law. For example, in Rom 13:8-10

Paul lists some specific commands from the OT, and makes it clear that he

expects believers to fulfill them. If some of the moral norms of the OT law

are still binding on believers, then it is difficult to see how Christ can be the

absolute end of the law.4



2. Messianic Age Ends Age of Law


            A view related to the above one is that Paul believed that the era of law

has come to an end with the arrival of the Messianic era. When Rom 10:4

says that "Christ is the end of the law," the point is that Christ inaugurated

the Messianic age, and since the Messianic age has begun the law is no

longer in force. This view is often defended by showing that it was a com-

mon Jewish conception that the law would be abolished with the onset of

the Messianic epoch.5


3 H. Raisanen, Paul and the Law (Philadelphia: Fortress, 1983) 54-55; E. Kasemann, Com-

mentary on Romans (Grand Rapids: Eerdmans, 1980) 282-83; W. Schmithals, Der Romerbrief
Ein Kommentar
(Gutersloh: Gerd Mohn, 1988) 370; W C. Linss, "Exegesis of telos in Romans

10:4," BR 33 (1988) 6, 10-11; F Hahn, "Das Gesetzesverstandnis im Romer- and Galaterbrief,"

ZNW 57 (1976) 50; S. Westerholm, Israel's Law and the Church's Faith: Paul and His Recent

Interpreters (Grand Rapids: Eerdmans, 1988) 130; C. K. Barrett, "Romans 9:30-10:21: Fall and

Responsibility in Israel," Essays on Paul (Philadelphia: Westminster, 1982) 147; H. Schlier, Der

Romerbrief (HTKNT; Freiburg: Herder, 1977) 311; O. Michel, Der Brief an die Romer (MeyerK;

Gottingen: Vandenhoeck & Ruprecht, 1966) 255; G. Delling, "te<loj," TDNT 8.56; R.

Aldrich, "Has the Mosaic Law Been Abolished?" BSac 116 (1959) 322-35; A. van Dulmen,

Die Theologie des Gesetzes bei Paulus (SBM 5; Stuttgart: Katholisches Bibelwerk, 1968) 126.

4 Of course, all of these verses in Romans could be interpreted in another way. For a more

detailed defense of the ongoing validity of the law see T. R. Schreiner, "The Abolition and

Fulfillment of the Law in Paul," JSNT 35 (1989) 47-74; K. N. Snodgrass, "Spheres of Influ-

ence: A Possible Solution to the Problem of Paul and the Law," JSNT 32 (1988) 96, 99, 105-7.

5 J. A. Fitzmyer, "Paul and the Law," A Companion to Paul: Readings in Pauline Theology (ed.

M. J. Taylor; New York: Alba, 1975) 75, previously published in The Jurist 27 (1967) 18-36;

H. J. Schoeps, Paul: The Theology of the Apostle in the Light of Jewish Religious History (Phila-

delphia: Westminster, 1961) 171-75; A. Schweitzer, The Mysticism of St. Paul the Apostle (Lon-

don: A. C. Black, 1931) 191-192; van Dulmen, Die Theologie des Gesetzes, 126. For a careful

evaluation of the evidence see W. D. Davies, Torah in the Messianic Age/or the Age to Come

(Philadelphia: SBL, 1952).

                                          PAUL'S VIEW OF THE LAW                      115


            The fatal defect in this theory is the weakness of the alleged Jewish

evidence.6 Adequate proof is lacking in rabbinic literature that the law

would in fact be abrogated during the Messianic age. Moreover, even if

such a theory could be defended in rabbinic literature, there is no clear

evidence in Paul for such a theory. Neither Rom 10:4 nor any text from

anywhere else in Paul (e.g., Galatians 3) says that the law has come to an

end now that the Messianic era has arrived. Finally, even if one were to say

that Rom 10:4 and Galatians 3 do teach that the law has ended now that

the Messianic age has been inaugurated, then the same objection we noted

for the first view would apply, viz., Paul could not have taught that the law

has ceased to have any binding authority on believers since he cites moral

norms from the law as authoritative for the church.



3. Law Has Ended as a Way of Salvation


            Other scholars claim with a closely related theory that the law has come

to an end as a way of salvation.7 Righteousness in the OT era was via the

law, but now that Christ has come right standing with God is no longer

based on the law. There is some ambiguity regarding what scholars mean

when they say that salvation was by law in the Mosaic era, but now that

Christ has come salvation is only through him. Presumably some are merely

saying that although salvation in the OT was still by faith, such faith

involved offering sacrifices and the performance of other commandments in

the OT law. Now that Christ has come sacrifices and other prescriptions of

the law are no longer necessary. The sacrifice of Christ has replaced the OT

cultus. The idea that the sacrifice of Christ has replaced OT sacrifices is

surely in accord with Pauline theology, but it is hardly evident that Paul

is proclaiming the end of the OT law and sacrificial system in this sense in

Rom 10:4. No discussion on the atoning work of Christ is to be found here.

We shall argue below that there is a better way to explain the flow of

thought in Rom 10:3-5.

            Other scholars who see the law as coming to an end as a way of salvation

seem to be suggesting that there are two different ways of salvation, one


6 Cf. P. Schafer, "Die Torah der messianischen Zeit," ZNW 65 (1974) 27-42; E. Bammel,

"No<moj Xristou?," SE III (TU, 88 [1964]) 120-23.

7 P. Althaus, Der Brief an die Romer (NTD; Gottingen: Vandenhoeck & Ruprecht, 1959) 108;

H. W. Schmidt, Der Brief des Paulus an die Romer (THKNT; Berlin: Evangelische

Verlagsanstalt, 1963) 175; R. Mohrlang, Matthew and Paul: A Comparison of Ethical

Perspectives (SNTSMS 48; Cambridge: Cambridge University Press, 1984) 27; J. Reumann,

"Righteousness" in the New Testament (Philadelphia: Fortress, 1982) 88; R. N. Longenecker,

Paul: Apostle of Liberty (Grand Rapids: Baker, 1964) 144-47; G. E. Ladd, A Theology of the New

Testament (Grand Rapids: Eerdmans, 1974) 502-3; E. G. Gulin, "The Positive Meaning of the

Law According to Paul," LQ 10 (1958) 116; Delling, TDNT 8.56; A. Nygren, Commentary on

Romans (Philadelphia: Fortress, 1949) 379-80; J. Munck, Christ and Israel: An Interpretation of

Rom. 9-11 (Philadelphia: Fortress, 1967) 84; van Dulmen, Die Theologie des Gesetzes, 126.



based on the law and one based on the gospel.8 If this is what some scholars

have in mind, then this is not a convincing solution. Paul appeals to both

Abraham and David (Rom 4:1-8) to teach that salvation has always been

by faith, and that there is not a distinct way of salvation in the OT More-

over, Rom 9:31-32 demonstrate that Paul does not criticize the Jews for

pursuing the law. The problem is the way they pursued the law, i.e. "not from

faith but as from works."


4. Christ Is the End of the Ceremonial Law


            It has also been claimed that Christ is the end of only part of the law, viz.,

the ceremonial law.9 However, it is not at all clear in this context that Paul

is referring to only part of the law, nor does this view explain adequately

why righteousness is now available since the ceremonial law has been set

aside. Is salvation by law more easily attainable with the moral law in force?


5. The Exclusivity of the Law Is Set Aside


            Some claim that the point here is that Christ is the end of the exclu-

siveness of the law. Now salvation is also available to the Gentiles, and the

Jews of Paul's day have wrongly limited it to themselves.10  There is little

doubt that Paul focuses on the inclusion of the Gentiles in Romans 9-11 (cf.

9:24-26; 10:11-13, 19-20; 11:11-22). But this is not the central theme of

Romans 9-11. In these chapters God's faithfulness with respect to his prom-

ises for the Jewish people (cf. Rom 9:6) is the theme.11  Moreover, the specific

problem in Rom 9:30-10:3, I have argued elsewhere, cannot be limited to

the nationalism of the Jews.12 Practices which separated Jews from Gentiles,

such as circumcision, Sabbath, and food laws, are not even mentioned in

this section of the letter. It seems that the most natural way of reading Rom

9:32 and 10:3 is to see the Jews faulted for attempting to be righteous on the

basis of their works, and these works cannot be limited to part of the law.

Thus, a critique of works-righteousness in a broad sense is evident in this


8 A number of scholars in the first category listed above may be of this persuasion as well.

The lack of precision in the way this view has been expressed makes it difficult in some cases

to delineate specifically what some scholars have in mind when they say the law has come to

an end as a way of salvation.

9 So, e.g., C. Haufe, "Die Stellung des Paulus zum Gesetz," TLZ 91 (1966) 171-78.

10 M. A. Getty, "An Apocalyptic Perspective on Rom 10:4," HBT 4-5 (1982-83) 97, 100;

id., "Paul and the Salvation of Israel: A Perspective on Romans 9-11," CBQ 50 (1988) 466-67;

F. Refoule, "Romains X,4. Encore Une Fois," RevBib 91 (1984) 339; J. D. G. Dunn, Romans

(WBC; Dallas: Word, 1988) 2:598; F. Watson, Paul, Judaism and the Gentiles: A Sociological

Approach (SNTSMS 56; Cambridge: Cambridge University Press, 1986) 165; van Dulmen, Die

Theologie des Gesetzes, 127.

11 So also B. L. Martin, Christ and the Law in Paul (NovTSup 62; Leiden: Brill, 1989) 133.

12 See "Israel's Failure to Attain Righteousness in Romans 9:30-10:3," TrinJ 12 (1991)


                                          PAUL'S VIEW OF THE LAW                            117


text. And even though Paul proclaims the inclusion of Gentiles in Romans

9-11, the Jews are not specifically reproved for being too exclusive in Rom

9:30-10:8. Instead, they are censured for failing to obey the law and for



6. Christ Is the Goal of the Law


            An increasingly popular interpretation, which was also prominent, if not

dominant, in the history of the church,14 is the conception that Christ is the

goal of the law.15 A more extended critique will be given of this interpre-

tation in view of its increasing popularity and its historical significance.

            Robert Badenas' claim that te<loj must be translated teleologically in

Rom 10:4 is debatable,16 for—whatever one makes of the term outside the

NT—in the Pauline corpus and the rest of the NT the semantic range of

the word is used more commonly with a temporal rather than a teleological

meaning. Curiously even Badenas' own summary of Pauline usage could be

interpreted to support such a conclusion:17 (1) twice the word means

"fully" or "completely" (2 Cor 1:13; 1 Thess 2:16); (2) three times it


13 Similarly, F. Mailer's view ("’Christus [ist] des Gesetzes Ende zur Gerechtigkeit fur

jeden, der glaubt,’ [Rom 10:4]," in PaulusApostat oder Apostel? [ed. M. Barth et al.; Regens-

burg: F. Pustet, 1977] 31-44]) that Paul is speaking of the end of the law only for the Gentiles

but not the Jews is not persuasive. Paul indicts the Jews in these verses because they were

attempting to establish their own righteousness (Rom 10:3), not because they were imposing

the law on the Gentiles. For an effective refutation of Mufner see Schmithals, Romerbrief, 370.

14 See the historical surveys of Badenas and Nestingen cited in n. 1 above.

15 D. P. Fuller, Gospel and Law: Contrast or Continuum? (Grand Rapids: Eerdmans, 1980)

84-85; C. T. Rhyne, Faith Establishes the Law (SBLDS 55; Chico: Scholars, 1981) 103-4; id.,

"Nomos Dikaiosynes and the Meaning of Romans 10:4," CBQ 47 (1985) 492-93; L. Gaston, "For

All the Believers: The Inclusion of Gentiles as the Ultimate Goal of Torah in Romans," Paul

and Torah (Vancouver: University of British Columbia Press, 1987) 130; C. E. B. Cranfield, A

Critical and Exegetical Commentary on the Epistle to the Romans (ICC; Edinburgh: T. & T

Clark, 1975, 1979) 2.519-20; B. Reicke, "Paulus caber das Gesetz," TZ 41 (1985) 247-49; F.

Fluckiger, "Christus des Gesetzes te<loj," TZ 11 (1955) 153-54; P W. Meyer, "Romans 10:4 and

the ‘End’ of the Law," The Divine Helmsmen: Studies on God's Control of Human Events,

Presented to Lou H. Silberman (ed. J. L. Crenshaw & S. Sandmel; New York: Ktav, 1980) 65-66,

68; W. S. Campbell, "Christ the End of the Law: Romans 10:4," Studia Biblica 1978: III. Papers

on Paul and Other New Testament Authors. Sixth International Congress on Biblical Studies (ed.

E. A. Livingstone; JSNTSup 3; Sheffield: JSOT Press, 1980) 74-77; G. E. Howard; "Christ the

End of the Law: The Meaning of Romans 10:4ff," JBL 88 (1969) 333; J. Ziesler, Paul's Letter to

the Romans(Philadelphia: Trinity Press International, 1989) 257-58; Badenas, Christ the End,

114-17; W. C. Kaiser, Jr., "Leviticus 18:5 and Paul: Do This and You shall Live (Eternally?)"

JETS 14 (1971) 26; J. E. Toews, The Law in Paul's Letter to the Romans (Ph.D. dissertation,

Northwestern University, 1977) 220-42; G. N. Davies, Faith and Obedience in Romans: A Study

in Romans 1-4 (JSNTSup 39; Sheffield: JSOT, 1990) 1187-89; R. Bring, "Paul and the Old

Testament: A Study of the Ideas of Election, Faith, and Law in Paul, with Special Reference to

Rom. 9:30-10:13," ST 25 (1971) 45-46; Snodgrass, "Spheres of Influence," 107.

16 See his word study in Christ the End, 38-80. Against Badenas, see Dunn, Romans 2.589.

17 Badenas, Christ the End, 78-79. We omit the use of te<loj in Rom 13:7 since it refers to

the paying of taxes.



denotes "the eschatological end" (1 Cor 1:8; 10:11; 15:24); (3) twice "final

destiny" (2 Cor 11:15; Phil 3:19); and (4) five times it is teleological (Rom

6:21-22; 10:4; 2 Cor 3:13; 1 Tim 1:5). It should be observed that the first

three categories above match the semantic range of "end" more than they

do "goal." It cannot be denied that the range of te<loj is dynamic, and thus

it does not always refer to a temporal end. But Badenas' claim that the

translation "goal" is lexically required in Rom 10:4 is at least debatable

even from his own presentation of the evidence.

            What is even more significant is that, contrary to Badenas, 1 Tim 1:5

seems to be the only clear example of the word te<loj meaning "goal" in

the Pauline corpus. The other four examples Badenas lists are all disputed.

The two uses of te<loj in Rom 6:21-22 should be translated as "outcome,"

or "result," not "goal." The words "outcome" or "result" signify an

inevitable result, while "goal" suggests an intended purpose.18 Paul says of

evil deeds that "the end [te<loj] of those things is death" (v. 21). Con-

versely, "the end [te<loj]" of sanctification "is eternal life" (v. 22). Surely

the "goal" of wickedness is not "death"! When Paul speaks of the te<loj

of wickedness, he is referring to the "result," "consequence," or "out-

come" of evil behavior. The parallelism of the verses indicates that the word

te<loj should be construed similarly in v. 22.19

            Contrary to Badenas, the meaning of te<loj in 2 Cor 3:13 is most likely

"end" not "goal."20 This is suggested by the participle katargoume<nou,

which modifies te<loj in v. 13. The verb katarge<w in this context refers to

the passing away or cessation of the old covenant (cf. 2 Cor 3:7, 11).21  2 Cor

3:11 makes this particularly clear. The covenant which is "passing away"

(katargou<menon) is contrasted with one that is "remaining" (me<non). One

cannot separate in 2 Corinthians 3 the end of the splendor on Moses' face (v. 13)

from the passing away of the old covenant (v. 11), for Paul uses the cessation of

glory on Moses' face as an illustration of the passing away of the old covenant.22

            Nonetheless, Badenas' claim that te<loj means "goal" in 2 Cor 3:13 is

still a possibility. To interpret te<loj as goal, however, probably reads too


18 All results, of course, may be construed as the intended purpose of God. One needs to

be careful, though, of defining terms on the basis of this truism.

19 Interestingly Badenas himself (Christ the End, 74) links Rom 6:21-22 with 2 Cor 11:15 and

Phil 3:19 earlier, but then he places Rom 6:21-22 in a different category in his conclusions (pp.


20 Badenas, Christ the End, 75.

21 L. L. Belleville (Reflections of Clog: Paul's Polemical Use of the Moses-Doxa Tradition in 2

Corinthians 3.1-18 [JSNTSup 52; Sheffield: JSOT, 1991] 204-5) argues that the word katarge<w

means "fading." But support for this definition is not strong. The evidence points to katarge<w

meaning "to bring to an end," "nullify," and "abrogate." Rightly R. B. Hays, Echoes of

Scripture in the Letters of Paul (New Haven: Yale University Press, 1989) 134-35; O. Hofius,

"Gesetz and Evangelium nach 2. Korinther 3," in Paulusstudien (WUNT 51; Tubingen: Mohr,

1989) 96-99.

22 Badenas' comments (Christ the End, 75) on this text are quite murky so that it is difficult

to understand his interpretation.

                                     PAUL'S VIEW OF THE LAW                                 119


much into the word in this context. Linguistically, it is preferable to see

redundancy at work here. Paul uses the redundant expression "the end of

what is passing away" to drive home his point.23 What is particularly

instructive is to note that in 2 Cor 3:13 there is a prepositional construction

(ei]j to> te<loj). In every other passage in the NT where there is a preposition

before the word te<loj,  it never means "goal" or even "outcome" or "re-

sult." In fact, in seven of these texts the temporal meaning is clearly

present.24 The temporal meaning is quite possibly present in four other

texts with a prepositional phrase,25 and once again the meaning "goal" is

not possible in these texts. The prepositional phrase ei]j to> te<loj in 2 Cor

3:13, therefore, most probably means "to the end."

            The above discussion does not prove that te<loj refers to a temporal end

in Rom 10:4, but it does show that the theory that it often means "goal"

in Paul cannot be sustained. In fact, the meaning "goal" is indisputably

present in only one text in the Pauline corpus (1 Tim 1:5), while the tem-

poral meaning is quite common.26 Both interpretations are possible given

the use of the word, but the way Paul usually utilizes the term causes one

to expect the meaning "end."27 Thus, the meaning "end" seems preferable

linguistically to "goal" unless there are compelling contextual reasons for

preferring "goal."28 I will try to show later that such contextual reasons are

not present.

            It is also argued by some that the racing imagery of Rom 9:30-33 suggests

that "goal" is the most appropriate translation of te<loj.29 Belief in Christ


23 For some helpful comments on redundancy see M. Silva, Biblical Words and Their Meaning:

An Introduction to Lexical Semantics (Grand Rapids: Zondervan, 1983) 153-55.

24 Matt 10:22; 24:13; Mark 13:13; 1 Cor 1:8; Heb 3:14; 6:11; Rev 2:26.

25 Luke 18:5; John 13:1; 2 Cor 1:13; 1 Thess 2:16. The use of the preposition with the plural

te<lh (1 Cor 10:11) is not included here since the meaning of the word in the singular is what

is being investigated.

26 I have already presented evidence which shows that in prepositional phrases the tem-

poral meaning predominates. The temporal meaning for te<loj is also clearly present in

contexts in which it is not the object of the preposition. Cf. Matt 24:6, 14; Mark 3:26; 13:7;

Luke 1:33; 21:9; 1 Cor 15:24; Heb 7:3; 1 Pet 4:7; Rev 21:6; 22:13. A temporal meaning is

probably present in Matt 26:58. On the other hand, the only NT texts besides 1 Tim 1:5 which

could mean "goal"—as I read the evidence—are 1 Pet 1:9 and Luke 22:37.

27 Hofius ("2. Korinther 3," 110--11) shows that Badenas' observations on the grammatical

character of Rom 10:4 are not accurate. In particular, Badenas thinks he has found exact

parallels between Rom 10:4 and other texts in the NT and Greek literature. Hofius points out

that he fails to see that te<loj in Rom 10:4 is a predicate nominative, while in these other

texts—which he sees as grammatically parallel— te<loj; is a subject nominative.

28 The arguments against te<loj meaning "goal" also apply to those who see te<loj as

referring to "summation," "completion," or "fulfillment" here. For this latter interpretation

see K. Barth, Church Dogmatics 2/2 (Edinburgh: T. & T Clark, 1957) 244-45; P. von der

Osten-Sacken, Romer 8 als Beispiel paulinischer Soteriologie (FRLANT 112; Gottingen:

Vandenhoeck & Ruprecht, 1975) 254-55. Badenas (Christ the End, 36-37) also points out the

weaknesses of te<loj meaning "summation," "completion," or "fulfillment."

29 Badenas, Christ the End, 114-15; Gaston, "The Inclusion of Gentiles," 130; Fluckiger,

"Christus des Gesetzes te<loj," 154; Campbell, "Romans 10:4," 76.



is the appropriate goal, say these scholars, of pursuing the law in faith. This

suggestion is flawed because it ignores the immediate context of 10:4, and

jumps back to 9:30-33. In 10:1-3 Paul has ceased to use the racing imagery

of 9:30-33 where he speaks of Israel pursuing righteousness, and thus it is

inappropriate to import that imagery from 9:30-33 into the specific context

of 10:1-4.30

            Final arguments put forward in favor of "goal" are the larger context of

Romans 9-11 and the general Pauline theology of law.31 In this regard it is

said by these scholars that the very thesis of Romans 9-11 is found in 9:6

where Paul says that God's word has not failed with respect to Israel. How

could Paul say this if he were asserting that Christ is the end of the law?

Moreover, Paul's overall view of the law is one that suggests continuity be-

tween law and gospel, not contrast.32

            Even though we agree with the general thesis of the above statements,

these are not telling arguments for the meaning "goal" in Rom 10:4. Both

of these arguments appear to be directed against those who see an absolute

discontinuity between the law and gospel.33 But Rom. 10:4, if te<loj is

translated as "end," need not, and as we shall argue below, should not be

construed as a global and overarching statement on the relationship be-

tween gospel and law. In other words, one can still translate te<loj as "end"

in this specific context and hold to a positive view of the law in Paul. Thus,

the general theological objections posed by those who espouse the trans-

lation "goal" are not decisive.


7. Christ Is the End and Goal of the Law


            Others think that both options are a possibility here, arguing that "goal"

and "end" combined together communicate the meaning of te<loj in Rom

10:4.34 Such a solution is unlikely, for there is no other text in Paul in which

te<loj; combines the meanings "end" and "goal." Heikki Raisanen suggests

that this solution is due to the inability of the interpreter to determine


30 So also Raisanen, Paul and the Law, 54.

31 Cf. here Badenas, Christ the End, 117-18.

32 On this point see Fuller, Gospel and Law.

33 It should be said that there is some discontinuity between the old era and new era in Paul

(cf. Gal 3:15-4:7; 2 Cor 3:4-18).

34 E.g., M. A. Seifrid, "Paul's Approach to the Old Testament in Romans 10:6-8," TrinJ

6 (1985) 7-8; E. J. Schnabel, Law and Wisdom from Ben Sira to Paul: A Tradition Historical

Enquiry into the Relation of Law, Wisdom and Ethics (WUNT 2.16; Tubingen: Mohr, 1985) 91;

F. J. Leenhardt, The Epistle to the Romans (London: Lutterworth, 1961) 266; U. Wilckens, Der

Brief an die Romer (EKKNT; Neukirchen: Neukirchener Verlag, 1978-82) 3.222-23; A. J.

Bandstra, The Law and the Elements of the World: An Exegetical Study in Aspects of Paul's

Teaching (Grand Rapids: Eerdmans, 1964) 105-6; Ladd, Theology, 502-3; F. F Bruce, The Epistle

of Paul to the Romans (TNTC; Grand Rapids: Eerdmans, 1963) 203; J. C. Beker, Paul the

Apostle: The Triumph of God in Life and Thought (Philadelphia: Fortress, 1980) 91, 106-7; C. K.

Barrett, A Commentary on the Epistle to the Romans (HNTC; New York: Harper & Row, 1957)


                                  PAUL'S VIEW OF THE LAW                                    121


which meaning is most convincing.35 As noted previously the weight of the

lexical evidence favors a temporal idea, and the comparative rarity of the

meaning "goal" weakens this interpretation.


8. Ceasing to Use the Law to Establish One's Righteousness


            I would like to suggest that Paul is speaking experientially in this text, so

that his point is that Christ is the end of using the law to establish one's own

righteousness.36 Those who believe in Christ cease using the law as a means

of establishing their own righteousness, for believers see that righteousness

comes through believing in Christ, and it cannot be attained by obeying the


            The logical relationship between vv. 3-4 is the primary support for this

view. The assertion that "Christ is the end of the law" is not merely an

abstract theological proposition which Paul suddenly inserts into the dis-

cussion. Instead, a ga<r joins 10:3-4, indicating that v. 4 is intimately wed-

ded to v. 3. One of the crucial issues, then, is how the relationship between

vv. 3 and 4 should be explained.

            Before the connection between the two verses can be adequately ex-

plained, a word needs to be said about v. 3 itself. "The Jews did not subject

themselves to the righteousness of God, being ignorant about the right-

eousness of God and seeking to establish their own." I have argued else-

where that the fault of the Jews in v. 3 cannot be limited to nationalistic

righteousness, as if Paul were saying that the sole problem of the Jews is that

they excluded the Gentiles from participation in covenantal blessing.37 The

main proposition in v. 3 is that the Jews "have not subjected themselves to

the righteousness of God." I understand this to mean that the Jews have not

submitted themselves to the divine activity of God by which he declares

those who trust in him to be righteous. The two participles (a]gnoou?ntej

and zhtou?ntej in v. 3 are causal, in that they explain why the Jews did not

submit themselves to the saving righteousness of God. The reasons given are

because they were ignorant of God's righteousness and because they were

trying to establish their own righteousness. Now these two reasons should


35 Paul and the Law, 53.

36 Longenecker, Apostle of Liberty, 152-53; S. K. Williams, "The ‘Righteousness of God’ in

Romans," JBL 99 (1980) 284; H. Hubner, Law in Paul's Thought (Edinburgh: T. & T. Clark,

1984) 138; R. Bultmann, "Christ the End of the Law," in Essays Philosophical and Theological

(London: SCM, 1955) 36-66, esp. p. 54; L. Morris, The Epistle to the Romans (Grand Rapids:

Eerdmans, 1988) 380-81; J. Murray, The Epistle to the Romans (NICNT; Grand Rapids: Eerd-

mans, 1959-65) 49-50; U. Luz, Das Geschichtsverstandnis des Paulus (BEvT 49; Munich:
Kaiser, 1968) 139-45, 156-58; Nygren, Romans, 389; W. Gutbrod, "
no<moj," TDNT 4.1075. A

similar view is held by Martin (Christ and the Law, 144). He says that Christ is the end of the

enslavement, condemnation, and death which the law brings. It should be said here that

agreement with Bultmann's position on this specific text does not necessitate an existentialist

interpretation of Paul.

37 See n. 12 above.



not be sharply distinguished since those who are ignorant of God's saving

righteousness, the gift of his grace, and his glory will inevitably try to

establish their own righteousness and godliness as a way to merit his


            I conclude that Paul is countering here a form of works-righteousness in

which the Jews thought that they could attain right standing with God by

their works. This is the most natural way of understanding the statement

that "they were seeking to establish their own righteousness." A parallel

verse in the near context, Rom 9:32, informs the reader that Israel failed to

attain righteousness via the law because they sought to attain righteousness

"as from works" instead of by faith. Since e@rga in Paul refers to "works"

in a general sense and cannot with warrant be limited to only part of the

law, and since there is no mention of matters like circumcision, food laws,

or Sabbath in the context, it is fair to conclude that Paul is saying that some

Jews thought they could obtain righteousness by doing what the law says.

            This short excursus on the meaning of v. 3 brings us back to the impor-

tant question of the relationship between the two verses. Paul's charge

against the Jews in v. 3 is that they did not submit themselves to God's

saving righteousness because they were seeking to establish their own
What is the connection when Paul then says, "For Christ is the end

of the law with reference to righteousness for everyone who believes"? Sam

Williams rightly observes that there is an implied proposition linking vv.

3-4.39 The implied proposition, says Williams, is that the Jews were wrong

in not subjecting themselves to God's righteousness. Another possibility is

that the implied proposition is that those who have believed in Christ have

submitted to God's righteousness. Which of these two is correct is not that

crucial since in either case it is clear in the context that the Jews should have

submitted to God's righteousness, and this submission would be expressed

by believing in Christ. Verse 4 then provides the reason why the Jews should

have subjected themselves to God's righteousness, viz., that Christ brings

to an end the attempt to establish one's own righteousness. The close con-

nection between vv. 3-4 demonstrates that Paul is not making some global

theological statement on the relationship between gospel and law in v. 4.

He is responding to the specific problem raised in v. 3 of people wrongly

using the law to establish their own righteousness. In v. 4 Paul points out

that those who believe in Christ cease using the law as a means of estab-

lishing their own righteousness.

            Such an interpretation understands ei]j as an adverbial preposition of

general reference, not as introducing a result or purpose clause.40 Mark

Seifrid's grammatical analysis shows that sic in such constructions often

signifies result, but even his study shows that there are exceptions, and thus


38 Cf. Cranfield, Romans 2.515.

39 Williams, "The Righteousness of God," 283-84.

40 So Longenecker, Apostle of Liberty, 152-53.


                                      PAUL'S VIEW OF THE LAW                             123

the key issue here is the existing context.41 The whole focus of the context

is on Jews who wrongly use the law to establish their own righteousness.

Verse 4 makes an experiential statement regarding this state of affairs which

we paraphrase as follows: Christ is the end of using the law to establish one's

own righteousness for those who believe.

            Some lodge a complaint against the exegesis we suggest on the grounds

that ei]j dikaiosu<nhn is closer to Xristo<j than it is to te<loj ga>r no<mou.42

But the latter phrase is moved up front for emphasis, and Seifrid rightly

argues that ei]j dikaiosu<nhn is not related to all that precedes but only to

the predicate nominative te<loj no<mou.43

            The words panti> t&? pisteu<onti support the idea that Paul is not making

a global statement on the relationship between gospel and law. Christ is not

the end of using the law for righteousness for all people. Verse 3 demon-

strates that some Jews wrongly try to use the law for their own righteous-

ness. Thus, v. 4 only claims that those who believe, who trust in Christ for

their righteousness, cease trying to use the law to establish their own


            Verses 5-8 provide a ground for v. 4 as the ga<r in v. 5 indicates.44 But

how do vv. 5-8 function as a ground for v. 4? I understand v. 5 as follows:

The one who performs the righteousness of the law will live if he observes

it. Implied in this verse is the idea that no one can keep the law, and thus

righteousness is not available through the attempt to keep the law. Vv. 6-8

teach that Christ has done what is impossible for people to accomplish.

Righteousness does not come by doing the law, for no one can perform it

perfectly; righteousness comes by trusting in Christ. Thus, vv. 5-8 ground

v. 4 in that they confirm that believing in Christ brings to an end any

attempt to gain righteousness by the law. Verse 5 plays an important role

in that it shows that the attempt to gain righteousness by law is futile since

no one can obey what the law demands.

            Before summarizing where we have gone, a false conclusion which could

be drawn from v. 4 should be addressed. Paul is not suggesting here that

before Christ came every Jew used the law to establish his or her own

righteousness, but now that he has come one should be saved by trusting

Christ. Paul explicitly teaches that Abraham (Rom 4:1-5; Gal 3:6-9) and

David (Rom 4:6-8) were saved by faith and not by works. We think Paul

mentions Christ in v. 4 because now that the fullness of time has come (Gal

4:4) the specific way in which one manifests reliance upon God and his

promises is by trusting the God who sent his Son to atone for sins (cf. Rom



41 Seifrid, "Romans 10:6-8," 9 n. 29.

42 Cranfield, Romans, 2:519-20 n. 2; E. P. Sanders, Paul, the Law, and the Jewish People

(Philadelphia: Fortress, 1983) 61 n. 114; Badenas, Christ the End, 116.

43 Seifrid, "Romans 10:6-8," 9 n. 30. In light of Seifrid's study Raisanen's contention (Paul

and the Law, 55 n. 59) that such an understanding is linguistically impossible is unconvincing.

44 So also Rhyne, Faith Establishes, 111; A. Lindemann, "Die Gerechtigkeit aus dem Gesetz:

Erwagungen zur Auslegung and zur Textgeschichte von Romer 10:5,"  ZNW 73 (1982) 239.



            In summary, it seems to me that the main problem with most interpre-

tations of Rom 10:4 is that scholars are trying to support their whole under-

standing of the relationship between the law and the gospel on the basis of

this text. Accordingly, great battles are fought over whether Christ is the

goal or end of the law. The issues in this theological dispute are utterly

crucial, and they need further discussion. But my thesis in this article is that

Paul has something more modest in view in Rom 10:4. The particular

problem he is countering is the human tendency to misuse the law to

establish one's own righteousness. The purpose of the text is not to provide

a programmatic statement on the relationship between gospel and law

Paul is responding to a specific problem, the use of the law to establish one's

own righteousness. It is not surprising, then, that Rom 10:4 would contain

an experiential statement, for Paul is reacting to an experiential problem.

Such an attempt to establish one's own righteousness is of great conse-

quence for Paul since those who do so have failed to submit themselves to

God's saving righteousness. They should have submitted to God's righteous-

ness since belief in Christ is the end of using the law to establish one's own

righteousness for all who believe. Paul is not, therefore, giving a weighty

theological pronouncement here on the relationship between the Testa-

ments. He is simply saying that those who believe in Christ will no longer

use the law to establish their own righteousness. They have submitted

themselves to the righteousness of God by trusting Christ for their salvation

(cf. Rom 10:6-8).

                               III. The Interpretation of Rom 10:5

            We have gotten ahead of ourselves since the interpretation of v. 5 is itself

quite controversial.45 The interpretation of v. 4 is coupled with one's inter-

pretation of v. 5. We shall analyze and critique three major interpretations,

and then defend our own.


1. Radical Discontinuity between Law and Gospel

            Most scholars see a marked contrast between v. 5 and vv. 6-8, although

there are still debates regarding what v. 5 is specifically saying. Some claim

that the only point in v. 5 is that no one can obey the law sufficiently,46 while

others argue that Paul is only critiquing legalism.47 We should examine


45 The varying textual readings in 10:5 are quite complicated. For a defense of the reading

in Nestle-Aland26 see Lindemann, "Romer 10:5," 231-37; B. M. Metzger, TCGNT 524-25.

46 So, e.g., Martin, Christ and the Law, 137; Westerholm, Israel's Law, 129; F. Thielman, From

Plight to Solution: A Jewish Framework for Understanding Paul's View of the Law in Galatians

andRomans (NovTSup 61; Leiden: Brill, 1989) 113-14; van Dulmen, Die Theologie des

Gesetzes, 127.

47 E.g., Rhyne, Faith Establishes, 104-6; id., "Romans 10:4," 494-95; Kasemann, Romans:

285; Schmithals, Romerbrief, 371-72; G. Klein, "Sundenverstandnis and theologia crucis bei

Paulus," in Theologia CrucisSignum Crucis: Festschrift fur Erich Dinkier zum 70. Geburtstag (ed.

                                      PAUL'S VIEW OF THE LAW                                125


briefly the arguments of those who see Paul as only opposing legalism in this

text, for such a tradition of interpretation has been enormously influential,

especially in Lutheran circles. It is asserted that the very attempt to gain

salvation by law is sinful whether it can be obeyed or not. Walter Schmi-

thals represents this view when he says that Paul rejects law righteousness

"weil der Versuch, aus dem Gesetz zu leben, als solcher fluchwurdig ist."48

            Some scholars also perceive a radical discontinuity between the "spirit"

and the "letter" in vv. 5-8. They assert that Paul in this context uses the

OT texts cited in vv. 6-8 against the OT text quoted in v. 5, for part of the

OT consists of "letter," while other portions are informed by the "spirit."49

The "letter," according to this view, is found in the citation of Lev 18:5 in

10:5, while the "spirit" is revealed in the citations in vv. 6-8. Such a

distinction between the "letter" and the "spirit" is supported respectively

by the use of gra<fei in v. 5 and le<gei in vv. 6-8.

            Contrary to the above interpretation Paul does not say that anyone who

performs the law will die. Instead, v. 5 explicitly says that the person who

performs the law will live (o[ poih<saj au]ta> a@nqrwpoj zh<setai e]n au]toi?j)

by obeying it. There is no warrant for concluding that doing the law leads to

death when Paul says precisely the opposite, viz., that doing the law leads

to life. Contrary to Schmithals, Paul's statement in v. 5 only makes sense

if it is assumed that no one can perfectly obey the law. The attempt to gain

righteousness by law is excluded precisely because no one has the ability to

put into effect what the law demands. Schmithals is correct in claiming that

Paul is opposing an attempt to be righteous by works in this text. But the

reason Paul sees this attempt as folly is because sinners can never obey the

law perfectly and thus are fools if they think they can put God in their debt

by their good works.

            To see a distinction between "letter" and "spirit" on the basis of gra<fei

and le<gei in vv. 5-8 is also unwarranted.50 This can be shown from Romans

9-11 alone. He uses the verb gra<fw in five other texts (Rom 9:13, 33; 10:15;

11:8, 26) in order to introduce OT citations. In all of these texts the OT is

cited to confirm an argument that Paul has just made. There is no indi-

cation at all that he considers such OT citations to be "letter" rather than

"spirit." Moreover, the noun grafh< is employed in three passages (Rom

9:17; 10:11; 11:2) to introduce three OT texts. Once again it is clear that

Paul is using these texts in support of his argument. We can conclude


C. Andresen and G. Klein; Tubingen: Mohr, 1979) 279-80; Lindemann, "Romer 10:5,"

243-46; Schlier, Romerbrief, 311; Schmidt, Romer, 175.

48 Schmithals, Romerbrief, 371. See also other scholars listed to the previous note.

49 So Kasemann, Romans, 286; Schmithals, Romerbrief 375; Klein, "Sundenverstandnis,"

279; Schlier, Romerbrief, 311; Michel, Romer, 256.

50 So Lindemann, Romer 10:5," 240; Badenas, Christ the End, 122-24; Toews, The Law in

Romans, 256-57; Wilckens, Romer 3.226; Refoule, "Romains X,4," 330.



therefore that there is no evidence from the introductory formulas used in

Romans 9-11 that Paul is distinguishing between "letter" and "spirit"

when citing the OT.51


2. Jesus Christ Is the Obedient One


            Some scholars, who see Paul as saying that Christ is the goal of the law

in v. 4, understand v. 5 as referring to the perfect obedience of Jesus

Christ.52 He is the a@nqrwpoj in v. 5 who has performed all that the law

says.53 The major difficulty with this interpretation is that it is hard to see

in the generalizing noun a@nqrwpoj a specific reference to Jesus Christ.54

Andrew Bandstra's attempt to locate a parallel in Phil 2:7-11 seems par-

ticularly strained,55 for the two passages are in remarkably different con-

texts, and the passages differ significantly with respect to the words used.

Bandstra's decision to focus on Phil 2:7-11 as a parallel text is all the more

surprising since a much closer parallel in wording and theme is evident

between Rom 10:5 and Phil 3:9, and this latter parallel would yield quite

a different interpretation as we shall see.


3. The Obedience of Faith


            Other scholars who see Christ as the goal of the law in v. 4 maintain that

v. 5 is referring to an obedience of the law which springs from faith.56 The

doing of the law in v. 5, then, is not a works-righteousness, but it is the result

of trusting in God. In this interpretation there is no contrast between v. 5


51 For the OT citations which are introduced with le<gw see Rom 9:15, 17, 25; 10:6, 8, 11,

16, 19, 20, 21; 11:2, 4, 9.

52 Barth, Church Dogmatics 2/2.245; Cranfield, Romans 2.521-22; Reicke, "Paulus uber das

Gesetz," 249-50; Bandstra, Elements of the World, 104; Campbell, "Romans 10:4," 77-78; R.

Bring, Christus and das Gesetz: Die Bedeutung des Gesetzes des alten Testaments each Paulus

and sein Glauben an Luther (Leiden: Brill, 1969) 36, 44-55; id., "Paul and the Old Testament,"


53 For this significance of a@nqrwpoj see Bandstra (Elements of the World, 104). Reicke ("Paul-

us uber das Gesetz," 250) sees support for this in the aorist participle poih<saj signifying once

for all action. He reads too much significance into the aorist participle, which is used to

designate undefined action. For a careful analysis of the aorist tense see F. Stagg, "The Abused

Aorist," JBL 91 (1972) 222-31.

54 It is interesting to note, therefore, that some scholars think a@nqrwpoj is used to stress the

inclusion of all people, both Jew and Gentile (so Howard, "Romans 10:4," 334; Toews, The

Law in Romans, 269, 283; Badenas, Christ the End, 121; Davies, Faith and Obedience, 198).

This later view also seems to be an overinterpretation. The term a@nqrwpoj is a generalizing

noun which refers to all people, but there is no particular emphasis on the inclusion of the

Gentiles in the use of the word in this context.

55 Bandstra, The Elements of the World, 103-4. Against the link with Phil 2:7-11 see Refoule,

"Romains X,4," 345; Seifrid, "Romans 10:6-8," 14.

56 Fuller, Gospel and Law, 85-88; Gaston, "The Inclusion of Gentiles," 130; Howard, "Ro-

mans 10:4," 335-37; Badenas, Christ the End, 118-25; Kaiser, "Leviticus 18:5 and Paul," 27;

Toews, The Law in Romans, 243-83; Davies, Faith and Obedience, 189-200.

                            PAUL'S VIEW OF THE LAW                                 127


and vv. 6-8; both texts speak of the obedience that comes from faith. The

following arguments are presented to support such an interpretation.

            The conjunction de< in v. 6 is usually translated adversatively as "but."

Those who defend the theory that there is continuity between vv. 5-6 claim

that such a translation is unwarranted. The conjunction de< often means

"and," and the context, it is claimed, favors this latter interpretation.57

Thus, v. 5 and vv. 6-8 do not refer to two different ways of righteousness

but one way of righteousness, for the obedience that springs from faith (vv.

6-8) naturally leads to a doing of the law (v. 5).

            Verse 5 cannot stand in contrast with vv. 6-8, according to those who

defend this interpretation, because Paul would never use the OT against

itself.58 That is, in v. 5 Lev 18:5 is cited, and in vv. 6-8 Paul alludes to Deut

9:4; 30:12-14 (and perhaps Ps 107:26). We can assume, these scholars af-

firm, that Paul wanted to convince the Jews of the credibility of his stance

regarding the OT law. But if Paul uses the OT texts alluded to in vv. 6-8

against the citation of the OT in v. 5, then no Jew would be persuaded of

his argument, for the Jews believed that there was a fundamental harmony

in OT Scripture. No argument which pitted OT scripture against OT

scripture would carry the day with Jews who valued the OT. Moreover,

Paul himself regularly appeals to the OT as authoritative, and thus it is

difficult to conceive of him as denigrating part of OT revelation.

            Those who see a harmony between the doing of the law and the righteous-

ness of faith argue that the OT contexts of the two texts are quite similar.

Lev 18:5 does not teach that Israel should obey the law in order to earn

salvation.59 Instead, as with the rest of the OT, this verse teaches that obe-

dience to the law would be the expression, the intended result of God's

saving work. The obedience demanded here refers to maintaining life in the

covenant, not acquiring life by good works. And since sacrifice could be

offered for sins committed, there is no thought in Leviticus of obeying the

law perfectly in order to gain salvation. Furthermore, an analysis of Deut

30:12-14 makes it clear that Moses speaks of doing the law. Deut 30:12-14

says three times that the law should be observed. These scholars conclude,

then, that the obedience of Lev 18:5 cannot be separated from the obedi-

ence of Deut 30:12-14.60 Both describe the obedience that springs from

faith. There is no contrast between the two texts in the OT nor in Paul.


57 Fuller, Gospel and Law, 67; Badenas, Christ the End, 123; Toews, The Law in Romans,
252-53; Davies, Faith and Obedience, 190-91; Fluckiger, "Christus des Gesetzes
te<loj," 155.

58 Fuller, Gospel and Law, 67-69; Badenas, Christ the End, 123; Davies, Faith and Obedience,
194; Fluckiger, "Christus des Gesetzes
te<loj," 155. Badenas (121) and Toews (The Law in
, 244-45) ask how the Jews could be wrong in pursuing righteousness by works if that is
what the law in fact teaches.

59 So Kaiser, "Leviticus 18:5 and Paul," 19-28; Howard, "Romans 10:4," 334; Toews, The

Law in Romans, 244-45, 253, 264-70; Davies, Faith and Obedience, 192-93.

60 Fuller, Gospel and Law, 85-86.



4. The Nature of the Contrast between Rom 10:4-5

            Despite some impressive arguments for continuity between Rom 10:5 and

10:6-8, it is much more likely that the relationship between these verses is

adversative rather than continuative. In the course of arguing for the view

that there is a contrast between v. 5 and vv. 6-8 I shall respond to the

arguments given in support of continuity between v. 5 and vv. 6-8.

            Those who opt for continuity between v. 5 and vv. 6-8 rightly remark

that de< can be adversative or continuative. An exegetical judgment must be

made on the basis of the immediate context rather than the use of this

conjunction. The following arguments indicate that the context supports an

adversative relationship between 10:5 and 10:6-8.

            The doing of the commandments of the law in Rom 10:5 (o[ poih<saj

au]ta<) is equivalent to the establishing of one's own righteousness in 10:3.  In

both verses Paul counters the idea that one can obtain righteousness

through works. The parallel between vv. 3 and 5 is strengthened by the

particular wording employed. Verse 3 says the Jews "did not subject them-

selves to the righteousness of God" because they "were ignorant of the

righteousness of God." The genitive qeou? which is used twice with the word

dikaiosu<nh in v. 3 is a genitive of source. It is a righteousness which comes

from God as a gift. In v. 5 the righteousness is not from God. It is "righ-

teousness which is from the law" (th>n dikaiosu<nhn th>n e]k tou? no<mou), and

it is based on "doing" (o[ poih<saj). The link between vv. 3 and 5 is as

follows: because the Jews did not know that righteousness was God's gift (v.

3), they tried to gain their own righteousness based on keeping the law (v. 5).

            In order to sunder the connection between vv. 3 and 5, it is claimed that

the verses are not parallel because the word no<moj is lacking in v. 3.61 This

objection is hardly persuasive, for the righteousness which the Jews tried to

establish (10:3) was based on the law. Rom 9:31-32 demonstrates that Israel

tried to attain righteousness by pursuing the law with a works mentality.

The pursuit of the law "as from works" is synonymous with "seeking to

establish their own righteousness" in Rom 10:3.62 The connection between

vv. 3 and 4 also shows that the attempt to establish one's own righteousness

in v. 3 is related to the law. The verses are connected with a ga<r, and v. 4

says that "Christ is the end of the law with reference to righteousness for

everyone who believes." Whatever one makes of the specific meaning of v.

4, the correlation between "law'' and "righteousness" in the verse shows

that the attempt to establish one's own righteousness in v. 3 is based on

the law.

            The argument presented above regarding the connection between Rom

10:3-4 can be expanded further. Even if we accept for the sake of argument

the meaning "goal" for te<loj in 10:4, there is still the implication that the


61 Davies, Faith and Obedience, 195-96.

62 Fuller (Gospel and Law, 71-79), who does not agree with our interpretation of Rom 10:5-8,

nevertheless rightly sees the parallel between Rom 9:31-32 and 10:3.

                                        PAUL'S VIEW OF THE LAW                             129


false righteousness of the Jews in 10:3 is based on the law. Let me explain

how this is so. Verse 3 says that the Jews did not submit themselves to God's

righteousness because they tried to establish their own. Verse 4 provides the

reason why (ga<r) they should have submitted themselves to God's righteous-

ness. Let us assume that Paul is saying that they should have submitted to

God's righteousness and forsaken their own because Christ is the "goal" of

the law. The connection between vv. 3-4, then, would indicate that the

Jews tried to pursue their own righteousness because they misread the true

goal or intention of the law. But if they failed to obtain righteousness be-

cause they did not see the goal of the law, then it follows that their own

righteousness in 10:3 was based on a misunderstanding of the law. My point,

then, is that even if we accept the view that te<loj means "goal" in v. 4,

the false righteousness of the Jews in v. 3 is still based on the law. It follows,

therefore, that both v. 3 and v. 5 describe righteousness by law, and if v. 3

refers to works-righteousness, then so does v. 5.

            An adversative relationship between vv. 5 and 6-8 is also supported by

the antithesis between doing and believing which permeates the text in Rom

9:30-10:13. Israel did not attain righteousness through the law because it

was pursued "as from works" (9:32). Israel had a zeal for God (10:2) which

was manifested in the establishment of their own righteousness (10:3).

These texts seem parallel to the idea of gaining righteousness by doing

(10:5). But Paul stresses again and again in this text that the way to obtain

righteousness is not by doing but by believing (Rom 9:30, 32-33; 10:4, 6, 8,

9, 10, 11). Nowhere in this context does Paul speak of a doing of the law

which stems from faith, although he does speak positively of obeying the law

elsewhere (Rom 8:4; 13:8-10; cf. Gal 5:14). To see a fulfillment of the law

which is grounded in faith in 10:5 sits awkwardly in the context of Rom

9:30-10:8, for the remaining verses posit an antithesis between doing and


            The close parallel between Phil 3:9 (mh> e@xwn e]mh>n dikaiosu<nhn th>n e]k

no<mou a]lla> th>n dia> pi<stewj) and Rom 10:5 (th>n dikaiosu<nhn th>n e]k tou?

no<mou) is powerful evidence supporting the idea that Rom 10:5 describes

works-righteousness.63 The wording of the two texts is almost exactly the

same (dikaiosu<nhn th>n e]k no<mou, Phil 3:9; th>n dikaiosu<nhn th>n e]k

no<mou, Rom 10:5). All scholars agree that Phil 3:9 speaks negatively of

"righteousness from law." It is extremely unlikely that the same phrase in

Rom 10:5 is being used positively. This interpretation is strengthened by the

fact that in both Phil 3:2-11 and Rom 9:30-10:8 Paul is responding to

Jewish opponents who insisted that Gentiles must observe the OT law to be

saved.64 The subject under discussion in Philippians 3 and Romans 10 is,

therefore, the same. Paul contends that faith in Christ is what is necessary


63 So also Rhyne, Faith Establishes, 105; Lindemann, "Romer 10:5," 239 n. 29.

64 For a defense of the view that the opponents in Philippians 3 were Judaizers see P. T.

O'Brien, The Epistle to the Philippians (NIGTC; Grand Rapids: Eerdmans, 1991) 26-35.



for righteousness, not observance of the law. Since these two texts deal with

the same subject and possess almost identical wording, we conclude that

they do not bear radically different meanings. In both verses Paul is ex-

cluding righteousness by works and affirming faith in Christ as the way of


            It should also be emphasized that nowhere does Paul speak positively of

"righteousness which comes from the law" (th>n dikaiosu<nhn th>n e]k tou?

no<mou, Rom 10:5; cf. Phil 3:9). The point we are making here is that the

Greek formulation e]k tou? no<mou suggests that the law is the "source" of

righteousness. Paul, as we have noted previously, speaks positively else-

where of believers keeping the law. But nowhere does he ever say that

righteousness comes "from" the law.65 He insists again and again that

righteousness comes from God and is his gift. Thus, he uses the phrase

dikaiosu<nh qeou? (Rom 1:17; 3:5, 21, 22; Rom 10:32; 2 Cor 5:21; Phil 3:9)

as a genitive of source on numerous occasions to underscore the truth that

righteousness is a gift of God.66 Righteousness cannot come "from" the law

because the law incites people to sin (Rom 5:20; 7:5, 7-13). Those who see

Rom 10:5 as a positive description of keeping the law do not appreciate

sufficiently the differences between what Paul says in Rom 10:5 and other

texts in which he speaks affirmatively of keeping the law. The notion that

righteousness "comes from" the law is contrary to the heart of Pauline


            The other correlation between Phil 3:9 and Rom 9:30-10:8--which

should not be missed—is the contrast between the righteousness which

comes from the law and the righteousness which is on the basis of faith.

Israel failed to attain righteousness because they did not seek it "by faith

but as from works" (Rom 9:32). Gentiles obtained "righteousness by faith"

(Rom 9:30; cf. 9:33). It is the one who "believes" (t&? pisteu<onti) who stops

using the law to establish his own righteousness (Rom 10:4). The "right-

eousness which comes from the law" (Rom 10:5) is contrasted with "the

righteousness by faith" (h[ e]k pi<stewj dikaiosu<nh, Rom 10:6). Phil 3:9

supports the claim that there is a contrast between the "righteousness

which comes from the law" and "righteousness by faith" in Rom 10:5-6.

In Philippians Paul goes a step beyond merely saying that his own "righteous-

ness" was not "from the law." He also affirms that he obtained the right-

eousness which is a gift from God on the basis of faith (th>n e]k qeou?

dikaiosu<nhn e]pi> t^? pi<stei). Phil 3:9, then, not only shares the same word-

ing as Rom 10:5 regarding "righteousness which is from the law." Paul also


65 Fuller (Gospel and Law, 86) and Davies (Faith and Obedience, 196-97) contend that Rom 10:5

should be distinguished from Phil 3:9 because the former passage does not speak of "one's own

righteousness" as the latter does. It is unwarranted, though, to demand that every element of

Phil 3:9 be reproduced in Rom 10:5.

66 The meaning of dikaiosu<nh in Paul is intensely debated, and the amount of literature

is enormous. The most satisfying solution has been suggested by D. Moo, Romans 1-8 (Wycliffe

Exegetical Commentary; Chicago: Moody, 1991) 65-70, 75-86.

                                       PAUL'S VIEW OF THE LAW                                 131


goes on to contrast his own righteousness with "the righteousness of God on

the basis of faith." Since Phil 3:9 and Rom 10:5-6 share the same wording

both regarding "righteousness from law" and "righteousness on the basis

of faith," we have good evidence that both texts should be interpreted

similarly. The parallel between Phil 3:9 and Rom 10:5 cannot be dis-

counted merely by saying that the former text is personal and autobio-

graphical, while the latter refers to a corporate reality.67 This observation

is correct, of course, but materially the texts still deal with the same issue.

Paul in Philippians 3 is using his previous experience as an example to

illustrate the false path into which the false teachers are trying to lure the

Philippians.68 Paul's personal experience was a corporate experience for the

opponents in Philippians! So too, what was a problem for Israel corporately

(Romans 9-10) plagued Paul personally (Philippians 3). The difference

between Romans 9-10 and Philippians 3 is that Paul is speaking of many

people in Romans who had the same problem which he formerly had

according to Philippians.

            Neither is it compelling to say that in Rom 10:5 the word "law" is not

used to describe a false righteousness as it is in Philippians.69 It is already

clear from Rom 9:32 that the law if it is pursued "as from works" can be

misused so as to establish one's own righteousness. The Jews thought they

were righteous precisely because of their obedience to the law. This fits

nicely with Rom 10:5 where the one who does the law expects to gain

righteousness from the doing of the commandments. The object of the

participle poih<saj; in v. 5 is the word au]ta<, and au]ta< indisputably refers

to the commandments in the OT law. It follows, then, that even though the

word "law" is not specifically present in v. 5, the concept is materially

present, for it is the commandments of the law which people would "do."

            Paul does not censure the actual doing of the commandments. What he

is suggesting is that no one keeps the law sufficiently. The reason he does not

elaborate on human inability to keep the law in v. 5 is that this is old ground

in Romans which has already been covered (1:18-3:20). What is astonish-

ing to Paul is that people who fail to obey the law still think they can gain

life by observing the commandments. Thus, Paul reminds the church that

perfect obedience, which is impossible, is needed to be right before God.

            Supporting the idea that Paul is speaking negatively of works-

righteousness in Rom 10:5 is his citation of Lev 18:5 in Gal 3:12.70  Most

commentators concur that in Gal 3:12 Paul quotes Lev 18:5 to contrast the

law and faith.71 He says, "But the law is not of faith, but the one who does


67 Cf. C. Muller, Gottes Gerechtigkeit and Gottes Volk: Eine Untersuchung zu Romer 9-11

(FRLANT 86; Gottingen: Vandenhoeck & Ruprecht, 1964) 73-74.

68 Schmidt (Romer, 174) rightly observes that Paul once was what the Judaizers now are.

69 So Fuller, Gospel and Law, 86..

70 So Rhyne, Faith Establishes, 105.

71 For representative examples see H. D. Betz, Galatians (Hermeneia; Philadelphia: Fortress,

1979) 147-48; F F. Bruce, The Epistle to the Galatians (NIGTC; Grand Rapids: Eerdmans, 1982)



them [the commandments of the law] shall live by them." It is improbable

that Paul is using Lev 18:5 in a different way in Rom 10:5 and Gal 3:12, for

both texts treat the same theme, i.e., whether or not righteousness is avail-

able by the law. Gal 3:12 also contains the same contrast between the law

and faith which we are contending is present in Rom 10:5-6. The burden

of proof is clearly on those who think Paul cites Lev 18:5 in two completely

different ways.

            Feeling the sting of this argument, a few scholars have suggested that

Paul describes the keeping of the law positively in Gal 3:12 as well.72 This

suggestion is completely improbable given the situation in the Galatian

churches and the structure of the argument in the letter. The Galatians

were under attack from opponents who insisted that they submit to circum-

cision to be part of the people of God (Gal 5:2-6; 6:12-13). The heart of the

letter (Gal 2:15-5:12) contains a response to these opponents. Paul labors

to prove that justification does not come by "works of law" (2:16; 3:2, 5, 10),

that the attempt to obtain righteousness by law leads to a curse (3:10), that

the law is not a source of life (3:21), and that people who are "under law"

are actually under the sway of sin (3:23, 25; 4:3, 8-10, 21-25). It is im-

plausible in the course of this argument that Paul would positively insert

the proposition that one who keeps the law will obtain life (Gal 3:12). Such

a statement would have played into the hands of the Judaizers, for it was

they who were demanding adherence to the law for salvation. I am not

denying that Paul affirms keeping the law at the end of Galatians (cf. 5:14),

but he only does this after he clears up the problems raised by the Judaizers.

            Daniel Fuller agrees that Paul uses Lev 18:5 in a negative sense in Gal

3:12. He tries to defend the idea, however, that the OT citation has a

different meaning in Rom 10:5.73 In support of this he notes that no in-

troductory formula is employed in Gal 3:12, while in Rom 10:5 Paul in-

troduces the citation by saying "Moses writes." The reference to Moses

signals, says Fuller, that in Rom 10:5 Paul is citing Lev 18:5 in accord with

its intended meaning in its OT context. Fuller's stimulating proposal

should be rejected. Omitting the introductory formula in Gal 3:12 is no

indication that Paul is inserting the legalistic interpretation of the verse by

the Judaizers. There is no introductory formula in Gal 3:11 either, and yet

there is no doubt that Paul considers the OT citation from Hab 2:4 to be

authoritative. If anything the inclusion of Moses in Rom 10:5 betrays the

fact that there is a contrast between 10:5 and 10:6-8, for elsewhere Paul

contrasts the new age with the era of law inaugurated under Moses (2 Cor


163; E. DeW. Burton, A Critical and Exegetical Commentary on the Epistle to the Galatians

(ICC; Edinburgh: T. & T. Clark, 1921) 167; R. Y. K. Fung, The Epistle to the Galatians (NICNT;

Grand Rapids: Eerdmans, 1988) 145-46. The specific nature of the contrast will not be

investigated in detail here. See my "’Works of Law’ in Paul," NovT 33 (1991) 239-240.

72 Davies, Faith and Obedience, 196; Toews, The Law in Romans, 279-82; Bring, Christer und

Gesetz, 62; cf. also Cranfield, Romans 2.522 n. 2; Reicke, "Paulus uber das Gesetz," 250.

73 Fuller, Gospel and Law, 88, 98-99.

                                            PAUL'S VIEW OF THE LAW                            133


3:4-18).74 In any case a decisive argument would be needed to defend the

idea that Paul uses Lev 18:5 differently in Gal 3:12 and Rom 10:5. The

similarity of subject matter and theme lead us to the conclusion that Paul

uses Lev 18:5 similarly in Gal 3:12 and Rom 10:5.A major objection to our

view is that such an interpretation means that Paul uses Lev 18:5 contrary

to the intended meaning of that text in the OT, and such a misuse of the

OT would never convince Paul's opponents.75 The best solution to this

difficult problem has been suggested by Moises Silva in an article which

examines Paul's use of Lev 18:5 in Gal 3:12.76  What Silva says about the use

of Lev 18:5 in Gal 3:12 also applies to Rom 10:5. It is not satisfying to

conclude that Paul is only citing the legalistic misinterpretation of Judaizers

in Rom 10:5, but his citation of the OT text is influenced by the scriptural

exegesis of his opponents. Paul's opponents believed that the law itself could

provide life; that it was the source of life. Thus, they pursued the law "as from

works," expecting to secure righteousness through their obedience. Right-

eousness here refers to right standing before God, and the Jewish mistake

was to think that they could establish their own righteousness, i.e., salva-

tion, by their obedience to the law (Rom 10:3). Paul explains in v. 4 that

those who believe in Christ cease using the law as a means of establishing

their own righteousness; they recognize that Christ is the source of life, not

the law. When Paul cites Lev 18:5 in Rom 10:5, his point is that no one can

attain righteousness or eternal life by obeying the law since no one can obey

sufficiently what the law demands.

            What Paul is criticizing, then, in Rom 10:5 and indeed in the entire

context of Rom 9:30-10:8 is the attempt to gain right standing with God via

obedience of the law. He is rejecting the idea that the law is a possible source

of life or righteousness, even though the perfect keeping of the law would

bring such righteousness (cf. Gal 3:10-12; Rom 3:19-20). Thus, when Paul

cites Lev 18:5 in v. 5 his citation of that text is influenced by his Jewish

opponents who put forward the verse in order to argue that the law is the

source of righteousness. Paul does not flatly state that their interpretation

is incorrect by explaining Lev 18:5 in context. Instead, he counters their

interpretation by citing Deut 30:12-14.77 Silva notes it is uncommon for NT


74 This point, however, should not be pressed since Paul clearly cites words of Moses as

authoritative elsewhere (Rom 10:19; 1 Cor 9:9). So Seifrid, "Romans 10:6-8," 13.

75 Murray (Romans 2.51) argues that Paul does not use Lev 18:5 in accord with its intended

meaning, but the text is lifted out of context because it aptly describes legalism.

76 M. Silva, "Is the Law Against the Promises? The Significance of Galatians 3:21 for

Covenant Continuity," in Theonomy: A Reformed Critique (ed. W. S. Barker and W. R. Godfrey;

Grand Rapids: Zondervan, 1990) 153-67, esp. 163-66.

77 Of course, Paul's citation of Deut 30:12-14; 9:4 and Ps 107:26 is controversial. For some

insightful comments on the OT texts cited see Thielman, From Plight to Solution, 113-14. There

is a diversity of opinion among scholars regarding the use of the OT texts here. Paul's use of

the OT is seen as arbitrary (C. H. Dodd, The Epistle of Paul to the Romans [MNTC; London:

Hodder & Stoughton, 1932] 166; Schmidt, Romer, 176; M. Black, "The Christological Use of

the Old Testament in the New Testament," NTS 18 [1981] 8-9; Rhyne, "Romans 10:4," 496),



writers to call into question the interpretation of opponents by setting forth

an opposing contextual argument of the text in question.78 He goes on to

say, “Jewish literature contemporary to the New Testament shows a similar

hesitation to score points by refuting the opponent's use of Scripture. And

the later rabbinic scholars, as a rule, refuted an argument based on Scrip-

ture by counteracting with a different passage, not by demonstrating faulty

hermeneutics.”79 In other words, Paul cites the OT in Rom 10:6-8 to show

that obeying the law is not the means of obtaining righteousness; rather

Christ has accomplished all that is needed for salvation. The appropriate

human response is a humble faith which accepts what God has done in


            The interpretation we are proposing does not deny that Paul could use

Lev 18:5 in another context as a way of describing life within the covenant

by the redeemed. What Paul objects to in Rom 9:30-10:8 is the use of the

law as the source of righteousness or life. This interpretation also explains

why the objection that perfect obedience to the law was unnecessary in the

OT is irrelevant.80 Atonement was provided for those within the covenant,

but Paul is opposing those who think they can gain entrance into the

covenant by good works. For those who try to establish their own right-

eousness the provision of sacrifices does not apply because on Paul's terms

they are not yet within the covenant. There are also statements made by

Paul (cf. Gal 2:21; 3:10-13; Rom 3:21-26) which imply that animal sac-

rifices no longer atone; only Christ's sacrifice is truly effective.


as a proverbial use of the wording of the OT so that there is not actually a citation (W. Sanday

and A. C. Headlam, A Critical and Exegetical Commentary on the Epistle to the Romans [ICC;

Edinburgh: T. & T. Clark, 1902] 289; Barrett, "Romans 9:30-10:21," 129; W. D. Davies, Paul

and Rabbinic Judaism: Some Rabbinic Elements in Pauline Theology [London: SPCK, 1948]

153-55; R. N. Longenecker, Biblical Exegesis in the Apostolic Period [Grand Rapids: Eerdmans,

1975] 114, 121-23), as dependent upon wisdom traditions (M. J. Suggs, "The Word is Near You:

Romans 10:6-10 within the Purpose of the Letter," in Christian History and Interpretation:

Studies Presented to John Knox [ed. W. R. Farmer, C. F. D. Moule, and R. R. Neibuhr;

Cambridge: Cambridge University Press, 1967] 299-11; Schnabel, Law and Wisdom, 247-49), as

dependent upon Targumic traditions (S. Lyonnet, "Saint Paul et 1'exegese juive de son temps. A
propos de Rom 10:6-8," in Melanges Bibliques redigees en l'honneur d'Andre Robert [Travaux de

1'Institute Catholique de Paris, IV; Paris: Boud & Gay, 1956] 494-506; M. McNamara, The New

Testament and the Palestinian Targum to the Pentateuch [AnBib 27; 2d printing, with

Supplement containing additions and corrections; Rome: Pontifical Biblical Institute, 1978] 73-

78). For a provocative analysis of the OT citations which argues that Paul appeals directly to the

OT text itself, and that none of the above answers is fully satisfactory, see Seifrid, "Romans 10:6-

8," 17-37. For an extended discussion of the text see also Toews, The Law in Romans, 284-315.

78 Silva, "Is the Law Against the Promises?" 165. For a similar interpretation in some

respects see H. N. Ridderbos, Paul: An Outline of His Theology (Grand Rapids: Eerdmans, 1975)


79 Silva, "Is the Law Against the Promises?" 165.

80 Cf., e.g., G. Howard, Crisis in Galatia: A Study in Early Christian Theology (SNTSMS 35;

Cambridge: Cambridge University Press, 1979) 53.

                           PAUL'S VIEW OF THE LAW                         135


                                         IV. Conclusion


            In conclusion, Rom 10:4 proclaims that Christ is the end of the law in the

sense that he is the end of using the law to establish one's own righteousness.

Thus, those interpreters are mistaken who maintain from this verse that

Christ is the absolute end of the law for the believer. But neither is Paul

asserting that Christ is the goal of the law. The purpose of Rom 10:4 is not

to provide some global statement on the relationship between the Testa-

ments! In the specific context Paul is simply asserting that those who put

their faith in Christ cease to use the law as a means of establishing their own

righteousness. The source of saving righteousness cannot come via law obe-

dience; faith in Christ is the only path to life.

            Rom 10:5 fits with such an interpretation of Rom 10:4. Paul in Rom 10:5

is not speaking of the righteousness of Christ, nor is he describing the

obedience of faith. Neither is he suggesting that the very attempt to do the

law is blameworthy. Rather, Paul is saying that righteousness does not come

through the law because the law cannot be obeyed perfectly, and yet people

still vainly try to impress God with their works. The problem, then, is both

a legalism and a failure to obey.81  Paul points out both in Rom 9:32-33 and

10:6-8 that the way to salvation does not lie in doing the law; it is obtained

by believing in Christ. Vv. 6-8 make it plain that Christ has provided all

that is necessary for salvation, and thus the way to obtain salvation is by

believing the gospel which Paul preached.



81 Cf. on this point R. H. Gundry, "Grace, Works, and Staying Saved in Paul," Bib 66

(1985) 18-19; Leenhardt, Romans, 267-70.




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