Rom 2:12 For all who have sinned apart from the law will also perish apart from the law, and all who have sinned under the law will be judged by the law.  13 It is not those who hear the law who are righteous before God, but those who do the law will be declared righteous.

These verses have generated considerable scholarly debate because they appear to teach justification by works.

So, how are we to understand the place of works (‘obedience to the law’) in relation to justification in this passage?

It is important to note that Paul does not here explicitly contrast faith and works.  Rather, he contrasts those who hear the law with those who do the law.

The main options are:-

1. Paul is being self-contradictory – that Paul is drawing on rabbinical thinking here, without bothering to assimilate it into, or reconcile it with, what he will say later about justification by grace.  So Bultmann.  But to suppose that Paul contradicts himself on a matter that was obviously of supreme importance to him, is highly implausible.

2. Paul is presenting a paradox – that both present justification by grace and future judgment according to works are taught by Paul (and James, for that matter), but that these must be held in tension.

3. Paul is quoting his opponents – This is the view of Roger Olson.  Some Jewish Christians had arrived in Rome, and were teaching the Gentile believers that they must observe the law of Moses in order to be saved.  Verses 14-16 are Paul’s answer to this: appealing to the law of love (cf. Rom 13).

4. Paul is proposing a hypothetical view – that Paul is teaching that those who obey the law would indeed be declared righteous, but there are in fact no such people, since, as this whole passage affirms, all are guilty before God.

Wright (Paul and the Faithfulness of God) rejects the idea that Paul is representing, and then refuting, an opponent’s position.  Rather, he avers, this text functions as part of Paul’s larger argument: what is theoretical possible in Rom 2:13 is regarded as practically impossible in Rom 3:20 because the universal effects of sin.

‘The implication is that such an exact conformity to [the law’s] demands is beyond the achievement of sinful man, a fact which receives explicit confirmation in the devastating accusation that begins at v17.’ (Wilson)

‘This is a theoretical or hypothetical statement, of course, since no human being has ever fully beyed the law, cf. 3:20.  So there is no possibility of salvation by that road.  But Paul is writing about judgment, not salvation.  He is emphasising that the law itself did not guarantee the Jews immunity to judgment, as they thought.  For what mattered was not possession but obedience.’ (Stott)

‘The course of his argument indicates that while a man would be justified if he were a “doer” of the law, yet, since no-one does it perfectly, there is no justification that way. (Bruce)

‘The logic of these verses assumes that there is no person who is able to obey God’s law sufficiently so as to become righteous before him.’ (Moo, NBC)

In his full commentary Moo argues that Paul is not speaking of final justification here, but rather of the standard by which that verdict wil be rendered.  The apostle is not attempting to present his whole teaching on faith and works here: he is offering one step in his argument.  In reality, no-one can really ‘do’ the law; moreover, Jews cannot rely on their covenant status while failing to be abeident to the law.  Longenecker appears to take a broadly similar view.

5. Paul is teaching that works are the essential evidence of faith – that obedience to the law is evidence of our justification, but not the ground of it.  Under this view, faith and works are inseparable.  Paul speaks, for example, of ‘the obedience of faith’, Rom 1:5, and of the ‘work of faith’, 1 Thess 1:3.  Because justification and obedience are so inextricably linked, Paul can speak of justification as having a future reference, Rom 2:13; 8:33; Gal 5:4-5, and of a judgment on the basis of works, Rom 2:12; 14:10; 1 Cor 3:15; 2 Cor 5:10.

‘Believers are justified on the basis of faith, seen not as a human work or merit, but as an expression and result of the grace of God. And believers are judged on the basis of their works, seen as the natural outcome, result and expression of justifying faith. Believers are justified by faith, and judged by its fruit. There is thus a strong connection between the past and future elements of justification-embracing faith and its outworking. Works are the visible demonstration of a real and justifying faith-not the dead faith of which James complained (Jas 2:14-24).’ (McGrath, DPL)

Cranfield:

‘That doing what the law commands is the decisive thing, and not just hearing it and knowing about it, was a truth familiar to the Rabbis; but, though Paul takes up a Rabbinic doctrine, he is giving it fresh content. In its context in Romans this sentence can hardly be intended to imply that there are some who are doers of the law in the sense that they so fulfil it as to earn God’s justification. Rather is Paul thinking of that beginning of grateful obedience to be found in those who believe in Christ, which, though very weak and faltering and in no way deserving God’s favour, is, as the expression of humble trust in God, well-pleasing in His sight.’ (Emphasis added)

Bird (The Saving Righteousness of God) concludes that ‘those who do the law’ are Gentile believers, who demonstrate evidence of their faith, in contrast to the Jewish interlocutor introduced at the beginning of the chapter.

For Matera, the phrase ‘doers of the law’ describes all those – Jews and Gentiles alike who are justified and observe the law because it is written on their hearts.

Siefrid (in an essay in Justification and Variegated Nomism, Volume II: The Paradoxes of Paul) rejects the hypotehtical view, arguing that the gospel works true obedience to the law in those who believe.

This is also the view of Hendriksen.

Conclusion: although view 5 is true, I am not convinced that it is the truth taught by this particular passage.  I incline towards view 4.

(Updated version of an article first posted in 2022)