Messianic Apologetics

Addressing the Theological and Spiritual Issues of the Broad Messianic Movement

What Does “Under the Law” Really Mean? – Introduction to Things Messianic Study

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This article addresses the clause “under the Law” (Grk. hupo nomon), how it is used, and what it means in its appropriate context in view of what both the Tanach and Apostolic Scriptures tell us about the significance of God’s Torah.

What Does “Under the Law” Really Mean? – Introduction to Things Messianic Study


Those of you who have been involved in Messianic things, for any elongated period of time, know that we can be a controversial group of people. Particularly, those of us who were raised in evangelical Protestantism, and have now become a part of the Messianic community, have questioned much of what we were taught in the past, testing it against Scripture. While contemporary evangelicalism did indeed give many of us a foundational grounding in the Word of God, and thankfully and gratefully presented with us the gospel of salvation available in Yeshua the Messiah (Jesus Christ), it is nevertheless a human religious system, and as such did present us with some non-Biblical teachings.

A huge struggle which has manifested today involves the place of the Old Testament, and in particular the Law of Moses, in the life of contemporary Believers. Many are of the firm belief that Jesus came to abolish the Torah or the Law of Moses, and see His followers be removed from the standard of holiness seen in the Old Testament. Today’s Messianic community of faith does not believe this to be true! Messianic people notably practice many of the things that historical Christianity has deemed unimportant but were adhered to and kept by Yeshua’s early followers. We keep the seventh-day Sabbath or Shabbat, we celebrate the appointed times of Leviticus 23, and we follow the kosher dietary laws. These are just a few Torah practices that most contemporary Christians believe are unimportant.

Many in the independent Hebrew/Hebraic Roots movement are seen to vehemently criticize, berate, and harass Christians who believe that the Law has been abolished. I am more reserved, in that there are many sincere Christian people who actually do follow a great deal of the Torah’s ethical and moral code, perhaps without realizing it sometimes—but then there are other Christian people who believe that it is necessary for Believers to be completely severed from God’s Instruction in the Tanach. Many have been subjected to bad theology regarding the whole of Scripture, with many unwilling to reconsider previous belief systems.

I do my best to focus on common beliefs and values first (Ephesians 4:1-6)—yet one of the reasons why problems can erupt, at times, between Christian and Messianic people, is because many Messianics do not know how to properly defend their faith and practice. Rather than examining Scripture, insulting terms are usually thrown around and fights ensue. This is most evident when Christians who oppose Torah obedience claim that we are “under the Law,” and that this is not a position in which born again Believers should want to find themselves. Sadly, in my opinion, much of the Messianic handling of this one phrase has been anything but proper. We must be able to properly respond to this and see how it is used in the New Testament.

This article addresses the clause “under the Law” (Grk. hupo nomon), how it is used, and what it means in its appropriate context in view of what both the Tanach and Apostolic Scriptures instruct about the significance of God’s Torah. We will examine Yeshua’s words on the matter of the Law of Moses. We will consider how a variety of Christians and Messianic teachers have handled this term. We will then test these claims against what the Apostle Paul says in his letters. When you finish reading, the next time a Christian may say that you as a Messianic person are errantly “under the Law,” you should be able to properly respond.

Blessings and Curses

Before examining the phrase “under the Law,” it is crucial to recognize the importance that the Torah is to play in the lives of God’s people. Should its instructions continue to guide God’s people today? Our Heavenly Father said in Deuteronomy 7:6, “For you are a holy people to the Lord your God; the Lord your God has chosen you to be a people for His own possession out of all the peoples who are on the face of the earth” (NASU). The Hebrew word qodesh specifically means, “apartness, sacredness, holiness” (BDB).[1] God’s people are supposed to be separate from all the other peoples of the world. Ancient Israel was to do this by keeping God’s commandments that were contained in His Instruction, the Torah:

“The Lord will establish you as a holy people to Himself, as He swore to you, if you keep the commandments of the Lord your God and walk in His ways. So all the peoples of the earth will see that you are called by the name of the Lord, and they will be afraid of you. The Lord will make you abound in prosperity, in the offspring of your body and in the offspring of your beast and in the produce of your ground, in the land which the Lord swore to your fathers to give you” (Deuteronomy 28:9-11, NASU).

If Israel would be faithful to obey God, then His people were promised by Him to be established as a holy people, and it would lead to their greatness. The Hebrew verb qum appears in the Hifil stem (casual action, active voice) and has a variety of possible applications in this text, including: “cause to arise, raise,” “fig. raise (to dignity, power),” and “erect, build” (BDB).[2] This is an indication that if Israel kept the commandments that it would become a great people and be blessed by the Lord. Deuteronomy 4:5-6 specifically said,

“See, I have taught you statutes and judgments just as the Lord my God commanded me, that you should do thus in the land where you are entering to possess it. So keep and do them, for that is your wisdom and your understanding in the sight of the peoples who will hear all these statutes and say, ‘Surely this great nation is a wise and understanding people’” (Deuteronomy 4:5-6, NASU).

Notice that by Israel’s obeying the Torah, it would be said of them that “Only a wise and understanding people is this great nation” (Alter). If Israel obeyed the Lord, the people would be blessed by Him—and being blessed by Him they would serve as a testimony to outsiders of His goodness. If there is anything that we need today, it is wise people who know Yeshua as Savior and can understand God’s Word with the power of the Holy Spirit—being examples of those blessed by Him! Deuteronomy 4:6 is a significant statement of mission and purpose. God’s people need to be able to discern things based on Scripture, and possess the ability to share His wisdom with others.

But what if the people did not heed the words of God’s Torah, and instead chose to disobey Him? Before Moses’ death at the end of Deuteronomy, the assembly of Israel was instructed to go to Mounts Ebal and Gerizim. They were divided up, with twelve distinct blessings and curses to be pronounced upon the tribes (Deuteronomy 27:1-26). They end with a final word: “‘Cursed is he who does not confirm the words of this law by doing them.’ And all the people shall say, ‘Amen’” (Deuteronomy 27:26, NASU).

This is not a light usage of Amein, or “verily, truly” (BDB).[3] The people of Israel were told that if they did not allow God’s Torah to be upheld and established as their ruling principles, that they would be cursed because of their sin and disobedience. In their being cursed, they would find themselves subject to the Torah’s penalties. Their answer to God’s request is so be it.

Scriptural history and the nature of fallen humanity demonstrate how Ancient Israel was not faithful in keeping the Torah. In fact, both the Lord and Moses knew this would happen. Deuteronomy chs. 29 and 30 detail the judgment and curses which would manifest because of disobedience. However, even though Ancient Israel was once disobedient to the Torah, there are still benefits and blessings to be gained by studying and implementing its direction. As Paul taught, “Therefore did that which is good become a cause of death for me? May it never be! Rather it was sin” (Romans 7:13a, NASU). Paul testified that the Torah is something which is “spiritual” (Romans 7:14), and “We know that the law is good if one uses it properly” (1 Timothy 1:8, NIV).

Our Heavenly Father gave His people the Torah and its commandments to demonstrate His love, and His desire to watch out and care for His people. Because of the love we should have toward Him, we should naturally want to follow what He has prescribed—especially as its commandments form the basis of proper ethics and morality. As Moses’ Teaching details,

“Now, Israel, what does the Lord your God require from you, but to fear the Lord your God, to walk in all His ways and love Him, and to serve the Lord your God with all your heart and with all your soul, and to keep the Lord’s commandments and His statutes which I am commanding you today for your good?” (Deuteronomy 10:12-13, NASU).

The Lord said that His commandments are l’tov lakha, “for your benefit” (ATS) or “well-being” (NRSV). The Torah was not given as something to place God’s people into legalism or be an unbearable yoke of slavery for them, but rather to provide them the best way to succeed on Planet Earth, both spiritually and physically. God certainly did not free Ancient Israel from Egyptian bondage via the Exodus, only to later guide them to Mount Sinai and place them in bondage to the Law!

Of course, over the centuries since Moses was given the task of teaching the Torah to Ancient Israel, there was disobedience to it. After the people entered into the Promised Land, there were struggles with how to implement the Torah, including a period of anarchy (Judges 17:6). Israel was at its peak during the reigns of Kings David and Solomon, yet because of Solomon’s idolatry and disobedience to the Torah, the Kingdom split. The Northern Kingdom of Israel was besieged, with many taken captive by Assyria because of its disobedience and idolatry. The Southern Kingdom of Judah was taken into Babylonian exile, for seventy years, likewise because of its disobedience and idolatry.

Upon their return, the Jewish exiles made it a point to teach the Torah publicly (Nehemiah 7:73-8:12). Religious Jews have taken the Torah very seriously because of past judgment incurred from disobedience. When Israel is fully restored in the Last Days, there will once again be a return to God’s Torah as the New Covenant is completely implemented (i.e., Jeremiah 31:31-34; Ezekiel 36:26-27).[4] And Bible readers also encounter how the Torah will go forth from Zion to the nations (Isaiah 2:2-4; Micah 4:1-4). In our day, we have witnessed many non-Jewish Believers in Yeshua, especially embracing their faith heritage in Israel’s Scriptures and taking the Torah very seriously, as these prophecies begin to manifest themselves. This, as you can imagine, is causing quite a stir.

What did Yeshua say?

By the time Yeshua walked the Earth, there were various sects in Second Temple Judaism which approached the Torah differently. The two parties most featured in the Apostolic Scriptures are the Pharisees and Sadducees. The Sadducees only accepted the Written Torah, Genesis-Deuteronomy, as being authorized Scripture, and did not regard what is considered the rest of the Tanach (Old Testament), the Prophets and Writings, as applicable. As a result, they had a very limited view of the world and did not believe in the resurrection of the dead, angels, demons, or miracles (Matthew 22:23; Acts 23:8). The Pharisees, in contrast, considered the entire Tanach as authorized Scripture, and they believed in the resurrection, angels, demons, and miracles. But they also believed in the validity of the Oral Torah or Oral Law, which were thought to compose various traditions carried down over the centuries which gave explanation to the commandments. This Oral Law was later written in the 200s C.E. and is what we now largely know as the Mishnah.[5] The Pharisees and the Sadducees made up the religious council known as the Sanhedrin.

Many people who read the Apostolic Scriptures or New Testament believe that the Pharisees were all antagonists against Yeshua. Of course, many of them were, but so were many Sadducees. Yet at the same time, many other of His followers were Pharisees—and Yeshua’s theology and that of His Disciples was closer to that of the Pharisees than that of the Sadducees. In fact, the Apostle Paul did indeed proclaim before the Sanhedrin, ani P’rush (UBSHNT) or egō Pharisaios eimi—“I am a Pharisee” (Acts 23:6). Surprisingly to some Paul did not say, “I was a Pharisee.”

If you make an effort to have an understanding of the First Century times in which Yeshua lived, and have committed yourself to Torah study, you will have a better background than most who read the Gospel narratives. Scholars do recognize how many of the statements appearing in the Apostolic Scriptures or New Testament, which may appear negative toward Judaism and its traditions, need to be understood within the context of internal debates over Torah application.[6] So, you are likely to discover that when Yeshua debates with the Pharisees, it is most often over Torah interpretation and application—internal debates—not abrogating or nullifying God’s commandments as is often viewed.[7]

So what were Yeshua’s words on the matter of the Torah? Consider what He said in Matthew 5:17-19 in His Sermon on the Mount:

“Do not think that I came to abolish the Law or the Prophets; I did not come to abolish but to fulfill. For truly I say to you, until heaven and earth pass away, not the smallest letter or stroke shall pass from the Law until all is accomplished. Whoever then annuls one of the least of these commandments, and teaches others to do the same, shall be called least in the kingdom of heaven; but whoever keeps and teaches them, he shall be called great in the kingdom of heaven” (Matthew 5:17-19, NASU).

These three verses of are of significant importance for those who believe that Yeshua is the Messiah and that He is the Word of God made flesh (John 1:14)—meaning that by living a perfect life He followed the Torah without error and is without sin. Because Yeshua is our example for living, all Scripture regarding the Torah must be interpreted through His words. The Apostle Paul concurred, “Whoever teaches” must “agree with the sound words of our Lord Jesus Christ” (1 Timothy 6:3, NRSV). No matter how hard it may seem to be, or how unpopular it may be, common claims that the Torah has been completely abrogated and that it is no longer relevant for today must be reconciled to Yeshua’s words. That is, if Yeshua’s words are indeed final.

So what was Yeshua communicating? When the Messiah said, “Do not think that I came to abolish the Law or the Prophets” (Matthew 5:17, NASU), He declared that His mission was not to do away with the Law of Moses, contrary to what a great number of Bible teachers and readers may think. The Greek verb translated here as “abolish” is kataluō, meaning, “to end the effect or validity of someth., put an end to” (BDAG).[8] He asserted quite clearly, “Think not that I am come to destroy the law, or the prophets” (KJV).

Yeshua affirmed what His precise intention was regarding the Torah: “I did not come to abolish, but to fulfill.” The Greek verb plēroō means “to make full, to fill, to fill up,” “to carry into effect, bring to realization, realize” (Thayer).[9] What this means is that in “fulfilling” the Torah, Yeshua came to live it properly as the right example, how His followers are to “Let your light shine before men in such a way that they may see your good works, and glorify your Father who is in heaven” (Matthew 5:16, NASU). Many do not agree with this, and instead think that the Messiah “fulfilled” the Torah only in a prophetic sense, thus abolishing it, and that it is not relevant to be followed or considered by Believers today. But “fulfill” is by no means a synonym for abolish! Yeshua’s next words indicate the correct context of the passage and what He intended His followers to understand:

“For truly I say to you, until heaven and earth pass away, not the smallest letter or stroke shall pass from the Law until all is accomplished” (Matthew 5:18, NASU).

This verse is confusing for some readers, because the KJV says, “till all be fulfilled.” However, the verb translated as “fulfilled” in the KJV of Matthew 5:18 is not plēroō, which is used previously in Matthew 5:17, but is rather ginomai, “to become” (Thayer).[10] “Fulfilled” is a misleading translation, because what the Messiah actually said was that until all is accomplished the smallest letter and stroke, or “jot and tittle” (KJV) of the Torah, will not pass away.

The Lord made a reference to Heaven and Earth passing away before the Torah passes away. Are Heaven and Earth still here? Yes. So why do we have those who say that the Torah is no longer for today? Have they somehow missed it?

We know that the validity and relevance of the Torah continues to this day, as Yeshua concluded His remarks with the following:

“Whoever then annuls one of the least of these commandments, and teaches others to do the same, shall be called least in the kingdom of heaven; but whoever keeps and teaches them, he shall be called great in the kingdom of heaven” (Matthew 5:18-19, NASU).

The Messiah attached eschatological rewards to those who would keep the commandments of the Torah and teach them to others, and eschatological penalties to those who would not keep the commandments and teach others to break them. The word “least” or elachistos is of extreme importance. AMG defines this as, “The least, minimal in magnitude,” “in number and quantity,” “in rank or dignity,” “in weight or importance.”[11] What does this mean? Does it mean that many who have taught that the Torah is no longer to be followed or considered by God’s people, are going to be given few rewards in God’s Kingdom?

It is not our place as human beings to judge the (eternal) status of anyone, but we must heed the Lord’s words and endeavor to follow His admonition.

The Torah was given to God’s people to be a blessing. Those who heed and obey its commandments are to experience the rewards of obedience. Those who disregard the Torah and disobey its commandments will be penalized and/or cursed. In today’s vernacular, we might say that the Torah can either be your “best friend” or your “worst enemy.” As Believers, we are indeed forgiven of our sin should we fall (1 John 1:9)—but we are to strive not to sin. The Apostle John wrote, “The one who keeps His commandments abides in Him, and He in him. We know by this that He abides in us, by the Spirit whom He has given us” (1 John 3:24, NASU).

So how does not being “under the Law” factor into all this?

What Christians Have Said About “Under the Law”

Before we examine the clause “under the Law” from a Messianic perspective, it is important that we recognize what a great deal of customary Christian handling of “under the Law” has concluded, so we can know what to respond to.

In the New American Standard Bible, 1995 Updated Edition (NASU), which is a widely used and respected literal evangelical Protestant version, the phrase “under (the) Law” appears in eleven verses in the English (Romans 2:12; 3:19; 6:14-15; 1 Corinthians 9:20-21; Galatians 3:23; 4:4-5, 21; 5:18). (Further on I will discuss how some of these verses cannot be literally translated with “under [the] Law.”) The example I have chosen to illustrate the standard Christian interpretation of “under the Law” is Romans 6:14-15, which says,

“For sin shall not be master over you, for you are not under law but under grace. What then? Shall we sin because we are not under law but under grace? May it never be!” (Romans 6:14-15, NASU).

John A. Witmer states the following in The Bible Knowledge Commentary, New Testament:

“The mention that believers are ‘under grace’ (v. 14) raised another aberrant idea that the apostle refuted. The question is, Shall we sin because we are… under grace instead of the Law?… Paul’s response was the same as before (v. 2): By no means![12]

This commentary equates being “under the Law” as having to observe the Law, employing the description “under grace instead of Law.” It concludes that when Paul said that Believers are “under grace,” they are no longer required to follow the Law of Moses, but at the same time that Believers are not permitted to sin. Yet if one does not follow God’s Law, is this not a license for sin? Something has to be present to define sin, right? This commentary has only said, “this can be done by following Paul’s instructions.”[13] Certainly while Paul’s letters are important for anyone who considers the Bible authoritative, is this enough?

What did the good Apostle Paul himself say in Romans 3:20? “[F]or through the Law comes the knowledge of sin” (NASU). The Apostle John further said, “Everyone who practices sin also practices lawlessness; and sin is lawlessness” (1 John 3:4, NASU). Sin is violation of God’s Torah. In 2 Corinthians 6:14 Paul admonished, “Do not be bound together with unbelievers; for what partnership have righteousness and lawlessness, or what fellowship has light with darkness?” (NASU). How can these unbelievers be practitioners of lawlessness if they are not breaking, whether knowingly or unknowingly, the Law of God? All of humanity is subject to the penalties of breaking the Law (Romans 3:19b).

Equating “under the Law” as following God’s commandments comes up short, because both the Apostle Paul and Apostle John testified that sin is defined by God’s Torah, and they admonished people to avoid lawlessness. As the Torah demonstrates, if you disobey its commandments then you will be cursed and/or penalized by God. If Believers are instructed by Paul not to sin, and the Scriptural definition of sin is defined as lawlessness or disobedience to God’s Torah—then Paul was actually telling Believers not to transgress the Law of Moses, contrary to what many of today’s Christians may believe.

Various Christian theologians need to do a better job of examining the whole of Scripture, especially if they tell us that Believers are to exclusively follow Paul’s instructions. When Paul said, “For this, ‘You shall not commit adultery, you shall not murder, you shall not steal, you shall not covet,’ and if there is any other commandment, it is summed up in this saying, ‘You shall love your neighbor as yourself’” (Romans 13:9, NASU), he was not just making this stuff up, so to speak. He was quoting directly from God’s Torah (Exodus 20:13ff; Deuteronomy 5:17ff; Leviticus 19:18). And if Paul upheld the commandments of the Torah as being valid and relevant instruction (or at least including some valid instruction) for Believers, then what does “under the Law” really mean?

The standard Christian interpretation of “under the Law” as being forced to follow God’s Torah also comes up short because of the position of unbelievers in this paradigm. Are unbelievers who have rejected salvation in the Messiah “under the Law” or are they “under grace”? Considering that Paul’s letters were written to regions of the Roman Empire where the non-Jewish, non-believing populus was not following the Law of Moses, this is something which needs to be seriously considered. Being “under grace” is something that is only available for those who know Messiah Yeshua and have been redeemed. Keep in mind that when one disobeys God’s Torah a person will face punishment. Would not the non-believing pagans in the communities to which Paul was writing be cursed by their sin: their idolatry, fornication, homosexuality, etc.? Rather than being under grace, would they not instead find themselves under the condemnation of God’s Law?

If these pagans were not “under grace,” then what were they “under”? They could not have been “under nothing.” Paul said in Romans 1:25, concerning the pagan world, that “they exchanged the truth of God for a lie, and worshiped and served the creature rather than the Creator” (NASU). Romans 1 in its entirety discusses how these people were turned over to sin. What was the status of these people? We often do not find a satisfactory answer by enough Bible teachers today.

What Messianics Have Said About “Under the Law”

What has the Messianic handling of the term “under the Law” been? Messianic people who believe that Torah obedience is something to be encouraged in today’s Body of Messiah have had a substantial amount of contemporary Christian teaching relating to the Law of Moses, which is engrained in the minds of many, to address. As a result, there are varied responses as to what “under the Law” really means.

Most of the Messianic people who I have encountered turn to the works of Messianic Jewish theologian David H. Stern, author of several books, including the Complete Jewish Bible and Jewish New Testament Commentary. He explains his opinion that the Greek clause hupo nomon, which is translated as “under (the) Law” in most Bibles, more accurately means “in subjection to the system which results in perverting the Torah into legalism.”[14] Using the example of Romans 6:14-15 given above, he translates these verses as,

“For sin will not have authority over you; because you are not under legalism but under grace. Therefore, what conclusion should we reach? ‘Let’s go on sinning, because we’re not under legalism but under grace’? Heaven forbid!” (Romans 6:14-15, CJB).

Justifying this rendering, Stern remarks in his Jewish New Testament Commentary that “The word twice translated ‘under,’ upo, means ‘controlled by’…or ‘in subjection to,’”[15] which leads him to conclude that the best translation of nomos is “legalism,” rather than just “Law” or “Torah.” While perverting the Torah of God into legalism is surely something that is wrong, critics of the Messianic Jewish movement have attacked Stern for subjectively rendering nomos as “legalism” in some places, and then as “Torah” in others. While Stern’s works have certainly helped the Messianic community, it is notable that his Complete Jewish Bible translation is not literal, and thus it cannot be used as a prime source work in refuting any anti-Torah attitudes which one may encounter in today’s New Testament theology.[16]

I believe that many Messianic people have misdiagnosed the problem of why contemporary Christians they encounter can be hesitant to consider a positive place for God’s Torah in their lives. Messianic Jewish authors Ariel and D’vorah Berkowitz comment in their 1996 work Torah Rediscovered, “First and foremost, the Torah is ‘God’s teaching.’…The word does not mean ‘law’; it means ‘teaching.’”[17] They further state that Bible translators could not just “break out of their centuries-old tradition” and “have chosen a translation of ‘law’ where Torah would have been the accurate translation.”[18]

The root problem of why many contemporary Christians are resistant to having a positive view of the Torah, is concluded by many Messianic people to be that both torah in the Hebrew Scriptures and nomos in the Greek Scriptures should be translated as Torah and not “law.” We should not doubt that the Hebrew term torah—derived from the verb yarah, meaning to “throw, cast,” “shoot (arrows),” and “direct, teach, instruct” (BDB)[19]—more accurately means “Teaching”[20] or “Instruction,” or just plain “Torah.” There have been some misunderstandings regarding its translation as “Law,” and some Christian people might think that God’s Torah is just legalistic rules and regulations. Yet even with this clarification explained to various Christians, I cannot concur that this is the primary problem.

It is only a modern phenomenon whereby the word “law” has come to have a negative connotation among many contemporary Christians, as law and order are good things. The Jewish scholars who translated the Hebrew Bible into Greek, contributing to the Greek Septuagint three centuries before Yeshua, thought the same thing, and thought that nomos, the Greek word for “law,” was the best rendering for torah. God’s Torah would be the ruling principles of a proper society. This carried into the Greek Apostolic Scriptures. Perhaps if they had known that in the future that “law” would come to have a negative meaning, they would have chosen something else, but we have to live with their decision.

To diagnose the translation of torah as nomos or “law” as being the primary problem is not appropriate, especially when the term “law” is used frequently in many modern Jewish Torah commentaries, and even the 1917 Jewish Publication Society version to translate torah. Modern Jewish teachers do not seem to have a problem with the term “law” as much as some Messianic people do. And, it would not even occur to most Christian Bible translators to possibly render nomos as “Torah” in English versions of the New Testament.

The primary problem of why many Christians do not want to a more positive view of God’s Torah as instruction to be followed, is something that many people are not willing to see, including many in the Messianic community. (And it certainly gives me no pleasure to mention it, either.) This reason is humanity’s inbred desire to disobey God, which results in sin and being cursed or penalized, just as the Torah teaches. Knowledge of God’s commandments can cause an unredeemed person to sin (Romans 7:13b), and if not dealt with assertively, can spread vociferously throughout a faith community. Consider what Paul wrote in 2 Thessalonians 2:7: “the mystery of lawlessness is already at work” (NASU). This epistle was written in about 50-52 C.E., only two decades after the ascension of Yeshua into Heaven.

By the end of the First Century, lawlessness or disobedience to the Torah grew to such an extent in parts of the ekklēsia, that we can understand the Apostle John’s poignant words where he said, “By this we know that we have come to know Him, if we keep His commandments. The one who says, ‘I have come to know Him,’ and does not keep His commandments, is a liar, and the truth is not in him” (1 John 2:3-4, NASU). John directly told His audience that if they did not follow God’s commandments, but at the same time claimed to know the Messiah, then they were speaking lies. And, most soberly for today, we must consider Yeshua’s own future word: “Because lawlessness is increased, most people’s love will grow cold” (Matthew 24:12, NASU).

We are now in an appropriate position to understand what “under the Law” really means.

What Scripture Says About “Under the Law”

The phrase “under (the) Law” is used in eleven verses in the English of the New American Standard, Updated Edition (Romans 2:12; 3:19; 6:14-15; 1 Corinthians 9:20-21; Galatians 3:23; 4:4-5, 21; 5:18), which is a widely used literal version by many evangelical Protestants, and is perhaps the most widely respected and used Christian Bible version in the Messianic community as well. We will use the NASU as our base of comparison for properly understanding what this means.

In the Greek, the clause correctly rendered as “under (the) Law” is hupo nomon. The preposition hupo, when appearing with an accusative case noun (indicating direct object), can mean “under, below; under the authority of” (CGEDNT).[21] Nomos is defined by AMG as “spoken in the NT mostly of the Mosaic statutes,”[22] meaning the Torah. Most just conclude that hupo nomon equates to meaning “following the Law.”

The most frequently offered, viable alternative, to hupo nomon meaning “following the Law,” is actually “under the condemnation pronounced by the law”—something recognized by examiners who do not believe that the Torah of Moses is not really to be followed by God’s people today.[23] One who is “under grace,” for example, would be considered forgiven of sin and innocent before God’s justice—a status that unredeemed sinners do not have. We will examine each of the eleven references where “under (the) Law” is used in the NASU English text. I have listed them in their most likely order of composition (Galatians, 1 Corinthians, Romans).

Is it possible for “under the Law” to not mean following the Law, but instead being subject to the condemnation of the Law upon sinners? Let us find out if this helps make better sense of these passages.

Galatians 3:23

But before faith came, we were kept in custody under the law [hupo nomon], being shut up to the faith which was later to be revealed(NASU).

Galatians 3:23, although usually interpreted that being “in custody” (NASU) or “confined” (RSV) pertains to being Torah obedient, has much greater significance when viewed from the vantage point that being “under the Law” means being subject to the Torah’s penalties pronounced upon sinners. Galatians 3:23 speaks of the fact that before one’s faith in Messiah Yeshua comes into their life, an unredeemed person was “imprisoned and guarded” (NRSV),[24] a direct consequence of sin. This position of the Torah changes when a man or woman receives Yeshua into his or her life, and receive forgiveness from sins. The redeemed person is released from bondage to sin, and is no longer “under the law.”

Redeemed Believers are released from the condemnation they once experienced under the Law, but they are not released from God’s high standard of holiness. For born again Believers, the Torah no longer serves the same purpose as it did prior to the salvation experience, having once been a harsh disciplinarian for those on the way to faith (Galatians 3:24).

Galatians 4:4-5

But when the fullness of the time came, God sent forth His Son, born of a woman, born under the Law [genomenon hupo nomon], so that He might redeem those who were under the Law [hupo nomon exagorasē], that we might receive the adoption as sons(NASU).

These verses are fairly easy to deduce involving “under the Law” as being subject to the Torah’s penalties or its condemnation upon sinners. Yeshua the Messiah entered into the world as a human, specifically “to free those under law” (TLV), human beings who stood condemned because of their disobedience to God. Yeshua entered into the world and was sacrificed as an atonement for human sin, so that the Torah’s curse could be lifted for all (Galatians 3:13). Via the power of Yeshua and His completed work on the tree, the curse of the Law has now been remitted for those who receive Him into their lives! Not being “under the Law” is directly tied to the redemption of human beings.

Galatians 4:21

“Tell me, you who want to be under law [hupo nomon], do you not listen to the law?(NASU).

Galatians 4:21 has been a cause of some misunderstanding, because the meaning of “under the Law” as being subject to the Torah’s punishments upon sinners is not often considered. When we can recognize the complex situation that Paul addresses in Galatians, it is not impossible for his admonition here to be understood in this light, but it does require Bible readers to reorient their approach to his letter. There was a sect of agitators in Galatia which said if you did not follow their “works of law,” being circumcised and formally converting to Judaism as a proselyte, that you could not be included among God’s people.[25]

The clear thrust of Galatians is that faith in God, and in His Messiah, is what reckons a man or woman as a member of God’s righteous own (Galatians 3:26). For the Galatians to go through formal proselyte circumcision to be reckoned as righteous, would be to revert to a pre-salvation state (Galatians 5:1-2) of no longer being “under grace.” So then to paraphrase, Paul was probably telling the Galatians, “You who want to be subject to the Torah’s penalties, do you not know what the Torah prescribes for your punishment?” His statement was used as a form of ironic rebuke.

Sadly, many theologians over the centuries have taken Paul’s letter to the Galatians out of its ancient First Century Jewish context, and have construed that this good Pharisee taught against God’s Torah and taught against the rite of circumcision. He did no such things; but he did place these things in proper perspective regarding faith in the Messiah. When Paul told these Galatians, “Behold I, Paul, say to you that if you receive circumcision, Messiah will be of no benefit to you” (Galatians 5:2, NASU), he was telling this group of people that if they thought circumcision and proselyte conversion would be the answers to their problems—then do not even think about them! He was not speaking to all people of all generations that physical circumcision is wrong, but placed this matter in proper perspective, emphasizing that it was not a salvation issue. Inclusion among the righteous occurs via faith in God, beginning with the example of Abraham (Romans 4:9-11).

Galatians 5:18

But if you are led by the Spirit, you are not under the Law [hupo nomon](NASU).

Knowing that “under the Law” can mean being subject to the Torah’s penalties, should allow this verse to make much more sense to Messianic people. Those who are not led by God’s Spirit are those who will break God’s Law (Romans 8:7). But in contrast, those who are truly led by the Holy Spirit will not be led to disobey the Lord, which would cause them to stand under the Torah’s penalties. This is because people who are led by the Holy Spirit will naturally obey the Lord and be blessed—just as the Torah says, because the Spirit is to write God’s commandments onto the redeemed person’s heart (Ezekiel 36:26-27).

The Holy Spirit does, though, go beyond the Torah, manifesting itself in the fruit of a Believer’s changed life (Galatians 5:22-23), providing discernment for life events where the Torah may not deliver any specific instruction or direction. This is what James D.G. Dunn properly describes in his Galatians commentary as “a spontaneity and adaptability to the demands of each specific situation which rules applied whatever the circumstances can never match.”[26] But the fruit of the Spirit is notably something, “against such there is no law” (Galatians 5:23, RSV), as its virtues surely align with the righteous tenor of God’s commandments.

1 Corinthians 9:20-21

To the Jews I became as a Jew, so that I might win Jews; to those who are under the Law, as under the Law [tois hupo nomon hōs hupo nomon] though not being myself under the Law [hupo nomon], so that I might win those who are under the Law [hupo nomon kerdēsō]; to those who are without law, as without law, though not being without the law of God but under the law of Christ [ennomos Christou], so that I might win those who are without law(NASU).

1 Corinthians 9:20-21 is problematic for many people, because first of all, it may seem as if a figure like the Apostle Paul wavered in his following of the Torah. Secondly, most Bibles have mistranslated 1 Corinthians 9:21 with “under the law of Christ.”

Did Paul waver in his Torah observance, being Torah observant around Jews, and then not being Torah observant around Greeks and Romans? If he did, then he would be in violation of his own word that he brought the good news or gospel to the Corinthians without malicious intent or deception (2 Corinthians 4:1-2). In this specific letter, he said later in 1 Corinthians 11:1, “Be imitators of me, just as I also am of Messiah” (NASU). If Paul was being truthful here, and Yeshua followed the Torah, then Paul followed the Torah as an imitator of the Messiah. Imitators of Paul are to likewise do the same.

What Paul intended by his remark “to the Jews I became as a Jew” (1 Corinthians 9:20a, NASU), was that he did his best to understand the specialized needs of his audience. These were the Jewish people who knew they stood under the condemnation of the Law, not being Believers in the Messiah redeemed from sin. Paul was free from the condemnation of the Torah, being a Believer in the Messiah. Similarly, when Paul said, “to those who are without law, as without law” (1 Corinthians 9:20b, NASU), he did his best to relate to the pagans at large who did not have specific knowledge of God’s Torah. This is probably best evident by Acts 17:22-23 when he was in Athens debating with the Athenians, making note of the Temple to the Unknown God which he viewed as a memorial to the Holy One of Israel (although the Atheninas did not know it). Paul communicated that one must do his or her best to relate to an audience, to best present them with the good news of salvation.

What did Paul mean when he said that he was not “without the law of God but under the law of Christ” (1 Corinthians 9:21b, NASU)? (Keep in mind that if Yeshua is indeed God, then the Torah of God is His Torah.) Sadly, the rendering of “under the law of Christ” in many Bibles is incorrect. It is a mistranslation because earlier in 1 Corinthians 9:20 hupo nomon is translated literally as “under the Law,” but hupo nomon Christou or “under the Law of Christ” is not what appears in 1 Corinthians 9:21. Rather, it is ennomos Christou, which Young’s Literal Translation renders as “within law to Christ,” and could also be understood as “in-lawed to Christ” or “in Messiah’s Torah” (TLV).

This can certainly change one’s evaluation of Paul’s thoughts. Ennomos means “what is within range of law and governed or determined by law” (AMG).[27] So by Paul saying that he was “within the Torah to Messiah” (1 Corinthians 9:21, PME), he followed the Torah as the Messiah demonstrated it; he was “within the framework of Torah as upheld by the Messiah” (CJSB; cf. Galatians 6:2). Paul’s obedience to the Torah was focused around Yeshua’s work in his life and the imperatives of the good news as first seen in the Torah (Genesis 12:3; Galatians 3:8), beginning with love for God and neighbor (Deuteronomy 6:5; Leviticus 19:18; cf. Mark 12:28-34; Matthew 22:36-40; Luke 10:25-28), and around the Messiah’s own decisive interpretation of Moses’ Teaching, which most would agree is mainly contained in His Sermon on the Mount (Matthew chs. 5-7).

Romans 2:12

For all who have sinned without the Law will also perish without the Law, and all who have sinned under the Law [en nomō] will be judged by the Law(NASU).

Many believe from Romans 2:12 that “under the Law” equates to a person having to follow the Torah, but this is neither an accurate assessment nor a proper translation. Paul described the state of two different groups of people relating to the judgment of God upon sinners. He first mentioned those who would anomos, “without law, lawless” (LS).[28] This describes a behavioral pattern of those who live without God’s Divine Law, and will thus die in this manner. This would have mainly been First Century, pagan Greeks and Romans. The person turned over to sinful behavior, not knowing whether something was sin or not, was still going to be judged by the consequences of such sin. Paul stated earlier in Romans 1:24 that “God gave them over in the lusts of their hearts to impurity” (NASU). By rejecting Him, such persons accept sin, they are delivered up to it, and they will be judged.

The second status detailed in Romans 2:12 is those who are en nomō, correctly rendered as “in law” (YLT) or “in the Torah” (PME). This would have mainly been First Century Jews, who had conscious possession of the Torah. It represents those persons who know the Torah of God, and from it know what is considered acceptable and unacceptable to Him via its commandments. Paul wrote that those who sin while “in the Law” are going to be judged by it. Their judgment is going to be much higher, because what is right and wrong is clearly laid out by the Lord and His commandments, whereas the person who just sins lawlessly, not quite knowing what God considers acceptable and unacceptable, may not be judged as severely (cf. Revelation 20:12-13).

The next verse, Romans 2:13, says, “for it is not the hearers of the Law who are just before God, but the doers of the Law will be justified” (NASU), as it is surely insufficient to simply know the Torah or exist en nomō (Romans 2:12, Grk.). The term translated “doers” in Romans 2:13 is poiētēs (sing.), “a doer, performer,” and “one who obeys or fulfils the law” (Thayer).[29] It is used in James 1:22, “But prove yourselves doers [poiētēs] of the word, and not merely hearers who delude themselves” (NASU). Its verb form, poieō, appears when Yeshua said, “whoever keeps [poieō] and teaches them, he shall be called great in the kingdom of heaven” (Matthew 5:19b, NASU).

Obviously, this does not at all speak against obeying the Torah, because otherwise the doers of the Torah would not somehow be considered justified before God (likely here pertaining to their demonstrating themselves as a part of His own).[30] In Romans 2:12, Paul spoke of the state of the person who lived lawlessly or without the Torah, and then the state of the person who lived according to its standards. This does not at all mean that one can be redeemed or eternally saved by human works. But rather with the correct understanding, “faith, if it has no works, is dead, being by itself” (James 2:17, NASU), we should see that works are natural evidence of they salvation experience, and they come naturally because of one’s love for the Lord.

Romans 3:19

Now we know that whatever the Law says, it speaks to those who are under the Law [en tō nomō], so that every mouth may be closed and all the world may become accountable to God(NASU).

The most literal rendering of Romans 3:19 is not with “under the Law” but rather “in the Law,” en tō nomō, “within the Torah” (TLV). What this means is that the Torah speaks directly to those who are within its sphere of influence, and who clearly or consciously know what it says. It is also said in Romans 3:19 that the entire world is somehow “accountable” (NASU) or “guilty” (NKJV) before God because of the Torah, likely because of basic principles of right and wrong impressioned on the human psyche via His image, which the Torah details in its commandments. Hupodikos specifically means, “Under sentence, condemned, liable, subject to prosecution” (AMG)[31]—a status for pas ho kosmos or the whole world.

Paul continued in the next verse, “for through the Law comes the knowledge of sin” (Romans 3:20b, NASU). One of the major intentions of the Torah is to reveal the sin in a human being’s life, and how the Torah will hold all to accountability. The Torah shows the world what it is guilty of and what it will be punished for, as “the mind set on the flesh is hostile toward God; for it does not subject itself to the law of God, for it is not even able to do so” (Romans 8:7, NASU). Yet, the mind set on the Spirit (Romans 8:5) is to subject itself to a spiritual Law from God (Romans 7:14). God’s Torah is to show born again Believers the best way to get the most out of their relationship with Him by obeying Him.

Romans 6:14-15

For sin shall not be master over you, for you are not under law but under grace [ou gar este hupo nomon, all’ hupo charin]. What then? Shall we sin because we are not under law but under grace [ouk esmen hupo nomon, all’ hupo charin]? May it never be!(NASU).

Is a born again Believer permitted to sin, and allowed to break the commandments of God’s Torah, because he or she is not “under law,” but instead is “under grace”? This was something that apparently various members of the assembly at Rome were thinking. Yet the Apostle Paul refuted it. Prior to salvation, the master of the unredeemed man or woman is sin, a status which causes a person to be “under law.” When Yeshua becomes a person’s Master, he or she changes and is “under grace.” Born again Believers are not to find themselves “under law,” precisely because they are covered by the blood of the Messiah. They are no longer subject to the condemnation pronounced by the Torah upon sinners, because sin is no longer their lord.

Believers who are born again and redeemed are not subject to the Torah’s punishments pronounced upon sinners; they are not “under law.” Romans 6:14-15 demonstrates one’s need to live responsibly being covered by God’s grace, living in obedience to Him. If we have been spiritually regenerated, we need to take to serious heart what Yeshua had to endure to take away the penalty of our disobedience to the Law via His sacrifice! Being redeemed from eternal punishment should be good motivation for us to obey God.

Our faith in Yeshua does not nullify our need to obey God, just as Paul has said, “Do we then overthrow the law by this faith? By no means! On the contrary, we uphold the law” (Romans 3:31, RSV). Obedience to God’s obedience comes as we emulate our Lord and Savior, and are transformed by His love.

Are you “under the Law”?

Take notice of the words of Deuteronomy 27:26: “‘Cursed is he who does not confirm the words of this law by doing them.’ And all the people shall say, ‘Amen’” (NASU). The Hebrew verb translated “cursed” is arar. “[T]he majority of ‘curse’ sayings with ‘ārar fall into one of three general categories: (1) the declaration of punishments…(2) the utterance of [something]…(3) the proclamation of laws…It is interesting that all these curse-sayings are a reflex[ion] of one violating his relationship to God” (TWOT).[32] When we violate the commandments of God’s Torah and fail to abide by its guidelines, we damage the relationship with our Heavenly Father that we should be having. Disobedience to the Lord certainly does not help the communion that we should be having with Him!

Yeshua the Messiah came to free men and women from slavery to sin, and from the curse of the Torah that hangs over sinners: “Messiah redeemed us from the curse of the Law, having become a curse for us—for it is written, ‘Cursed is everyone who hangs on a tree’ [Deuteronomy 21:23]” (Galatians 3:13, NASU). Paul stated Colossians 2:13-14,

“When you were dead in your transgressions and the uncircumcision of your flesh, He made you alive together with Him, having forgiven us all our transgressions, having canceled out the certificate of debt consisting of decrees against us, which was hostile to us; and He has taken it out of the way, having nailed it to the cross” (Colossians 2:13-14, NASU).

Contrary to popular belief, this certificate of debt is not God’s Torah, but is rather the curse pronounced in the Torah against sinners. Those who have received Yeshua into their lives and have been forgiven of their sin do not sit under the penalty of the Law, with the Torah ready to come crashing down upon their heads. But even so, this gives redeemed men and women no reason to disobey God—for obedience brings blessings and disobedience brings curses. When we disobey our Father, we damage the relationship that we have, or should be having, with Him.

So what might you have to change in your life so you can find yourself in obedience to the Lord—and hence not under any kind of denunciation from the Law?

In our day and age, our Heavenly Father is doing new and exciting things through the growth of the Messianic movement, as more and more Believers are drawn to their faith heritage in Israel’s Scripture and a Torah foundation. It is prophesied that when Israel is restored, “My servant David will be king over them, and they will all have one shepherd; and they will walk in My ordinances and keep My statutes and observe them” (Ezekiel 37:24, NASU). The heart of our Heavenly Father is that we each demonstrate our love for Him and obey Him: “Oh that they had such a heart in them, that they would fear Me and keep all My commandments always, that it may be well with them and with their sons forever!” (Deuteronomy 5:29, NASU).

Do we want to be blessed or do we want to be penalized? Do we want to have the best relationship with our Father as is possible? Or do we want to have a strained relationship? Consider these questions as you ponder whether following the Torah is important. Most importantly, make sure that you are a redeemed, born again Believer, who does not sit in fear, under the Torah’s condemnation.[33]


[1] Francis Brown, S.R. Driver, and Charles A. Briggs, Hebrew and English Lexicon of the Old Testament (Oxford: Clarendon Press, 1979), 871.

[2] Ibid., 878.

[3] Ibid., 53.

[4] Even though we surely partake of the New Covenant as Believers in Israel’s Messiah today (Hebrews 8:8-12), the New Covenant also involves a future return and restoration of the exiles of Israel to the Promised Land, as indicated by the wider statements of Jeremiah 31 and Ezekiel chs. 36-37.

[5] It is said that the Oral Torah was given to Moses (m.Avot 1:1), but this is certainly debatable. Some oral teaching or instruction was likely given to Moses that over time has been added to. The Mishnah (and similarly the Talmud and Midrash) contains valuable commentary on the Torah and historical information that should be consulted in theological exegesis, but should not be considered primary to the Biblical text itself.

[6] William L. Lane, Word Biblical Commentary: Hebrews 1-8, Vol. 47a (Nashville: Nelson Reference and Electronic, 1991), cxxvi.

[7] While broadly liberal, one resource to possibly consult includes Amy-Jill Levine and Marc Zvi Brettler, eds., The Jewish Annotated New Testament, NRSV (Oxford: Oxford University Press, 2011).

[8] Frederick William Danker, ed., et. al., A Greek-English Lexicon of the New Testament and Other Early Christian Literature, Third Edition (Chicago: University of Chicago Press, 2000), 522.

[9] Joseph H. Thayer, Thayer’s Greek-English Lexicon of the New Testament (Peabody, MA: Hendrickson, 2003), pp 517-518.

[10] Ibid., 115.

[11] Spiros Zodhiates, ed., Complete Word Study Dictionary: New Testament (Chattanooga: AMG Publishers, 1993), 561.

[12] John A. Witmer, “Romans,” in John F. Walvoord and Roy B. Zuck, eds., The Bible Knowledge Commentary: New Testament (Wheaton, IL: Victor Books, 1983), 464.

[13] Ibid.

[14] David H. Stern, trans., Jewish New Testament (Clarksville, MD: Jewish New Testament Publications, 1995), xxiv.

Here, Stern follows the conclusions of C.E.B. Cranfield, International Critical Commentary: Romans 9-16 (London: T&T Clark, 1979), 853.

[15] David H. Stern, Jewish New Testament Commentary (Clarksville, MD: Jewish New Testament Publications, 1995), 374.

[16] A selection of further explanations may be seen in the later released Barry Rubin, gen. ed., The Complete Jewish Study Bible (Peabody, MA: Hendrickson, 2016).

[17] Ariel and D’vorah Berkowitz, Torah Rediscovered (Lakewood, CO: First Fruits of Zion, 1996), 7.

[18] Ibid., 113.

[19] BDB, 435.

[20] The NJPS version of the Tanach widely renders torah as “Teaching.”

[21] Barclay M. Newman, Jr., A Concise Greek-English Dictionary of the New Testament, Revised Edition (Stuttgart: United Bible Societies/Deutche Bibelgesellschaft, 2010), 190.

[22] Zodhiates, Complete Word Study Dictionary: New Testament, 1015.

[23] Douglas J. Moo, “The Law of Christ as the Fulfillment of the Law of Moses,” in Wayne G. Strickland, ed., Five Views on Law and Gospel (Grand Rapids: Zondervan, 1996), 361.

[24] Grk. phroureō; meaning “to maintain a watch, guard” or “to provide security, guard, protect, keep” (BDAG, pp 1066-1067).

[25] Note how these “works of law” (Galatians 2:16[3x]; 3:2, 5, 10) are likely identity markers that would have defined an ancient Jewish religious sect, and how it followed the Torah (4QMMT). The specific “works of law” targeted in Galatians were tied up in the non-Jewish Believers being errantly persuaded that they had to be circumcised as proselytes, in order to truly be reckoned as members of God’s own.

[26] James D.G. Dunn, Black’s New Testament Commentary: The Epistle to the Galatians (Peabody, MA: Hendrickson, 1993), 288.

[27] Zodhiates, Complete Word Study Dictionary: New Testament, 591.

[28] H.G. Liddell and R. Scott, An Intermediate Greek-English Lexicon (Oxford: Clarendon Press, 1994), 74.

[29] Thayer, 527.

[30] “declared to be in the right” (Romans 2:12, Kingdom New Testament).

[31] Zodhiates, Complete Word Study Dictionary: New Testament, 1422.

[32] Victor P. Hamilton, “arar,” in in R. Laird Harris, Gleason L. Archer, Jr., and Bruce K. Waltke, eds., Theological Wordbook of the Old Testament (Chicago: Moody Press, 1980), 1:75.

[33] A more detailed exegetical analysis of this subject matter, “What Does ‘Under the Law’ Really Mean?—A Further Study,” is available in the author’s book The New Testament Validates Torah, where Romans 3:9; 7:6, 14; Philippians 3:6; Hebrews 7:11; 9:15, 22 (all RSV) are also addressed.


Introduction to Things Messianic

Are you new to the Messianic community? Do you have questions about what the Messianic movement, lifestyle, and theologies are all about? Do you need answers on a wide variety of issues with some detailed information? If these are the questions you have been asking, then Introduction to Things Messianic is a resource which will definitely benefit you.

Written to the new person investigating Messianic things, Introduction to Things Messianic is a compilation of articles which will inform the inquirer on a wide array of Messianic topics relevant to the current state and growth of our movement, including:

  • Is “the Church” truly a new group of elect?
  • Is the Torah or Law of Moses relevant for Believers today?
  • Who were the ancient Pharisees and what did they believe?
  • What are the ancient civilizations relevant to the Bible?
  • Am I required to keep the Sabbath?
  • What are the Biblical festivals?
  • Am I required to eat kosher?
  • Why do many Messianics use the proper name of God?
  • What do Messianics think about the end-times?
  • How do I properly grow in this new walk of faith?

These questions, and many more, are discussed and detailed in Introduction to Things Messianic. This book builds on the foundational material in Messianic Beginnings: An Introductory Study in a much more thorough way for those wanting an in-depth view of these basic issues. Introduction to Things Messianic can be used for a single person or a group Bible study, as study questions follow each chapter. This publication can also be used as an excellent primer to other publications available from Messianic Apologetics.

available in both paperback ($17.99) and eBook for Amazon Kindle ($9.99)

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