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The Covenant of Works
the Mosaic Covenant
& the Necessity of Obedience for
Salvation in the Day of Judgment

Pastor Mark Horne

Copyright © 2005

What follows is a modified excerpt from my PDF document defending Norman Shepherd.

When someone expounds the way of salvation found in the Westminster Confession and Catechisms and in the easily-accessible writings of the Reformed heritage, he often finds him embroiled in a debates about the covenant of works and the Mosaic Covenant. One is “proven” to be aberrant by allegations that one denies that God’s covenant with Adam was meritorious. I hope to show below that this is actually irrelevant. But since the claim is made so often, and is so flagrantly at odds with the Reformed Tradition, it deserves some scrutiny. Is it or was it ever essential to Reformed Orthodoxy to affirm a meritorious covenant of works?

The Nature of the Covenant of Works in Mainstream Reformed Theology

Supposedly, undermining the Covenant of Works is an essential feature of recent alleged movements departing from orthodoxy. Rick Phillips writes,

Along this path of ecclesiology over soteriology, ritual over reality, and covenant-keeping works over covenant-receiving faith, the authors of covenant confusion have one theological fortress they must overthrow. This is the classic Reformed understanding of God’s dealings with Adam as the covenant of works. Here is one point of uniformity among all those seeking to recast covenant theology and with it our doctrines of salvation: for their new ideas to be ushered in, the covenant of works must be ushered out. There is absolutely no room in their mono-covenantal scheme in which the law and gospel, along with faith and works, are no longer held in contrast but are meshed together in continuum.

Similarly, in resolution #2 the RCUS report condemning Norman Shepherd alleges as point g that: “He errs in confusion again in affirming that the ‘idea of merit is foreign to the way in which God our Father relates to his children,’ as if God has not required perfect obedience to His law as a condition for life.”

Confusion is often in the eye of the beholder. This statement appears to set up a false dilemma, claiming one must either affirm merit or else deny the necessity of perfect obedience. The targets of these accusations have never denied that God required from Adam perfect obedience as a condition of life. On the contrary, all have affirmed over and over again that the consequence of any sin can only be eternal separation from a holy God. The RCUS report itself admits that Shepherd affirms that Adam had no recourse to forgiveness in his original covenant with God. Obviously, without forgiveness, the only alternative to obedience is death. Denying the merit in the Adamic Covenant in no way implies that God did not require perfect obedience.

Rather the overwhelming Reformed consensus has merely been reiterated: that God’s covenant with Adam was one of grace and that the principle condition of that covenant was that Adam trust God for all his blessedness–a trust which could only result in perfect perpetual obedience for Adam as an unfallen creature. This is what historic Reformed orthodoxy has always affirmed:

We believe that man was created pure and perfect in the image of God, and that by his own guilt he fell from the grace which he received, and is thus alienated from God, the fountain of justice and of all good, so that his nature is totally corrupt (The French Confession, Article 9; emphasis added).

The French Confession was approved by John Calvin who himself taught the same thing. In 1536 he wrote in his first edition of the Institutes of the Christian Religion,

In order for us to come to a sure knowledge of ourselves, we must first grasp that Adam, parent of us all, was created in the image and likeness of God. That is, he was endowed with wisdom, righteousness, holiness, and was so clinging by these gifts of grace to God that he could have lived forever in Him, if he had stood fast in the uprightness God had given him. But when Adam slipped into sin, this image and likeness of God was cancelled and effaced, that is, he lost all the benefits of divine grace, by which he could have been led back into the way of life (emphasis added).

Twenty-four years later, Calvin still taught the same thing in his final version of the Institutes,

If man had no title to glory in himself, when, by the kindness of his Maker, he was distinguished by the noblest ornaments, how much ought he to be humbled now, when his ingratitude has thrust him down from the highest glory to extreme ignominy? At the time when he was raised to the highest pinnacle of honor, all which Scripture attributes to him is, that he was created in the image of God, thereby intimating that the blessings in which his happiness consisted were not his own, but derived by divine communication. What remains, therefore, now that man is stripped of all his glory, than to acknowledge the God for whose kindness he failed to be grateful, when he was loaded with the riches of his grace? Not having glorified him by the acknowledgment of his blessings, now, at least, he ought to glorify him by the confession of his poverty (2.2.1; italics added).

Indeed, it is a matter of Confessional orthodoxy for those in the continental Reformed tradition to affirm that upright, sinless creatures only live by the grace of God:

He also created the angels good, to be His messengers and to serve His elect; some of whom are fallen from that excellency in which God created them into everlasting perdition, and the others have by the grace of God remained steadfast and continued in their first state (The Belgic Confession, Article 12).

If even sinless angels are preserved by the grace of God for eternal life, why should Adam be any different? It is one thing to disagree with the Belgic Confession here, but it is altogether different to claim that it is a heretical compromise of the Gospel. Nor is this a simply a pragmatic matter of how we speak theologically. Luke 2.52 explicitly says that the grace of God was upon Jesus. Any claim that grace only refers to blessing shown to a sinner is an attack on the holiness of our Lord.

But there is more: William Ames writes in his Marrow of Theology of God’s covenant with Adam that, “In this covenant the moral deed of the intelligent creature lead either to happiness as a reward or to unhappiness as a punishment. The latter is deserved; the former is not” (1.10.11). Here William Ames is plainly “guilty” of the same crime as Norman Shepherd. According to logic of the RCUS Report, Ames is here denying that God required perfect obedience from Adam.

Or consider Fisher’s Catechism in questions and answers 30-32:

Was there any proportion between Adam’s obedience, though sinless, and the life that was promised?
There can be no proportion between the obedience of a finite creature, however perfect, and the enjoyment of the infinite God…

Why could not Adam’s perfect obedience be meritorious of eternal life?
Because perfect obedience was no more than what he was bound to, by virtue of his natural dependence on God, as a reasonable creature made after his image.

Could he have claimed the reward as a debt, in case he had continued in his obedience?
He could have claimed it only as a pactional debt, in virtue of the covenant promise, by which God became debtor to his own faithfulness, but not in virtue of any intrinsic merit of his obedience, Luke 17:10.

Note here the promissory nature of Adam’s relationship to God. Only by believing God’s promises and threats rather than Satan’s lies would Adam inherit eternal unmerited glory. Adam needed no forgiveness but he still lived by faith in God. He was disinherited for unbelief. Likewise, Zacharias Ursinus teaches in his Commentary on the Heidelberg Catechism that,

even if our works were perfectly good, yet they could not merit eternal life, inasmuch as they are due from us. A reward is due to evil works according to the order of justice; but not unto good works, because we are bound to do them as the creatures of God; but no one can bind God, on the other hand, by any works or means to confer any benefit upon him. Evil works, again, in their very design oppose and injure God, whilst good works add nothing to his felicity (p. 335).

Francis Turretin agrees with this overwhelming testimony. In the first place he defines “merit” in a way that rules out the possibility that a creature could merit anything from the Creator:

To be true merit, then, these five conditions are demanded: (1) that the “work be undue”–for no one merits by paying what he owes (Luke 17.10), he only satisfies; (2) that it be ours–for no one can be said to merit from another; (3) that it be absolutely perfect and free from all taint–for where sin is there merit cannot be; (4) that it be equal and proportioned to the reward and pay; otherwise it would be a gift, not merit. (5) that the reward be due to such a work from justice—whence an “undue work” is commonly defined to be one that “makes a reward due in the order of justice.” (17.5.4; p. 712).

This would lead one to expect that Turretin would deny that sinless “legal obedience” could ever be meritorious in God’s sight. Turretin explicitly meets this expectation. Even if sinless, “there is no merit properly so called of man before God” (Ibid). “Thus, Adam himself, if he had persevered, would not have merited life in strict justice” (Ibid). And, for a sinless being “the legal condition has the relation of a meritorious cause (at least congruously and improperly)” (12.3.6; p. 186; emphasis added). Joel Garver summarizes:

Having been educated at several prominent Reformed institutions on the Continent, Turretin returned to Geneva where he remained a professor of theology from 1653 onward. While there he published his greatest work, Institutio theologiae elenctiae from 1679-1685. Regarding prelapsarian grace in general, he writes that Adam’s “original righteousness can properly be called ‘grace’ or a ‘gratuitous gift’ (and so not due on the part of God, just as the nature itself also, created by him)” (Institutes 5.11.16).

Regarding the gratuitous promise of life held forth in the prelapsarian covenant of nature, Turretin argues that God promises not only bodily immortality, but also a transformed heavenly life. Had Adam persevered in obedience, the immortality of his body would only have been “through the dignity of original righteousness and the power of God’s special grace” (5.12.9). Moreover, Adam’s elevation to heavenly life would not have been a matter of mere justice, but also “the goodness of God” who is “plenteous in mercy” and by whom Adam would “be gifted” with heavenly life (8.6.6, 8).

For Turretin, not only was grace involved in Adam’s creation, in God’s promise, and in its reward, but Adam was also given “sufficient grace” by which to remain obedient to that first covenant, a grace that Turretin describes as “habitual and internal” (9.7.14-17).

Turretin’s nephew, Benedict Pictet, reiterated this Reformed Orthodox position. His Christian Theology was translated by Frederick Reyroux and it was published by the Presbyterian Board of Publication in Philadelphia before January of 1846. At that time, the issue of the Princeton Review announced the publication and declared,

In this small but compact volume, we have a comprehensive epitome of Theology; from the pen of one of the most distinguished theologians of Geneva. The great excellence of Pictet, is simplicity and perspicuity. He is, even in his large work, much less scholastic, than his predecessors, and less disposed perhaps to press his statements beyond the limits of certain knowledge. We are glad to see so sound and readable a book placed within the reach of all classes of readers (vol 18, issue 1, “Short Notices,” p. 180).

Pictet wrote regarding God’s covenant with Adam that it involved both promise and warning. The warning involves a rather straightforward exposition of the text of Genesis. Proving that a promise was also involved, however, requires some extrapolation, because the future reward is not stated in the text. Pictet reasons from God’s character saying:

With regard to the promise of the covenant, though it is not expressly laid down, it is sufficiently clear from the threatening of death, which is opposed to it; for although God owes nothing to his creature, yet as the whole scripture sets him forth to us as slow to anger and abundant in mercy, it is not at all probable, that God denounced upon man the threat of eternal punishment, and at the same time gave him no promise (p. 141).

Pictet also deals with the principle of the possibility of meritorious works later in his book. In dealing with the good works of a believer, and proving “the necessity of good works,” he goes on to point out that such necessary good works are not meritorious before God. In doing so he gives four reasons (pp 332, 333). At least two of these would apply to all creatures regardless of sin or innocence. First “a meritorious work must be one that is not due, for no one can have any merit in paying what he owes; but good works are due; ‘When ye shall have done all those things which are commanded you, say, We are unprofitable servants: we have done that which it was out duty to do’ (Luke 17.10).” Second, there must be a “proportion” between “the good work and the promised reward; but there is no proportion between the two in the present case; not even when the good work is martyrdom, the most excellent of all. For (all) ‘the sufferings of this present time are not worthy to be compared with the glory which shall be revealed,’ (Romans 8.18).”

But Pictet not only speaks of good works in general, but specifically addresses the issue of how good works would have related to Adam’s vindication and glorification if he had continued in faith and obedience rather than falling into unbelief and disobedience. He writes that “if the first man had persevered in innocence, he would have been justified by the fulfillment of the natural law which God had engraven on his heart, and of the other commandments which God might have enjoined on him; in short, by perfectly loving God and his neighbor” (p. 312). Thus, if Adam had persevered he would have been declared righteous and “acquired a right to eternal glory, not indeed as if he had properly merited it, for the creature can merit nothing from the Creator, but according to the free promise and Covenant of God” (Ibid.).

As can be seen by the fact that Pictet was translated, American theologians did not reject Turrettin’s faithful summary of the Reformed heritage; far less did they condemn it as a subversion of the Gospel. As Joel Garver writes in his essay, “The Covenant of Works in the Reformed Tradition,” of, A. A. Hodge’s Outlines of Theology, published in 1860.

In it he writes of the covenant of works, “It was also essentially a gracious covenant, because although every creature is, as such, bound to serve the Creator to the full extent of his powers, the Creator cannot be bound as a mere matter of justice to grace the creature fellowship with himself.” In his posthumously published Evangelical Theology: A Course of Popular Lectures (1890), Hodge similarly states, “God offered to man in this gracious Covenant of Works the opportunity of accepting his grace and receiving his covenant gift of a confirmed holy character” (167).

I will cut short my discussion list of evidence here, though it could be much much longer. Readers are directed to Joel Garver’s much more detailed and better-organized essay (http://www.joelgarver.com/writ/theo/covwor.htm) for more evidence, though it too could be much longer. Far from undermining it, those being criticized as “miscreants” and “aberrant” and worse are simply promoting Reformed theology in this area.

The Mosaic Covenant in Mainstream Reformed Theology

Even if the covenant of works were meritorious, it would nevertheless be entirely irrelevant to the accusations being made. It would be irrelevant because Adam violated the covenant of works at the beginning of history and since that time it has been impossible to receive glory from God in that way.

For these criticisms to work, not only must Adam be required to merit salvation, but somehow this same covenant must have been given to Moses on Mount Sinai. One Presbyterian critic writes regarding Norman Shepherd and his book The Call of Grace,

What, then, does Shepherd teach about the Mosaic Covenant, and the Law as its central feature? First, he denies that the Mosaic Covenant is a covenant of works. “At its core the Mosaic Covenant does not simply drive us to Christ, but further unfolds the gracious covenant relationship that the Lord established with Abraham and his children.” (COG 27)

Shepherd eviscerates the Pauline distinction between the Old and New Covenant, and, citing Matthew 5:20, states “The obligations of the New Covenant include not only faith and repentance, but also obedience.” (Emphasis added) (COG 47). It is hard, then, to see why the New Covenant is so superior to the Old, or how it is founded on “better promises.”

The RCUS report makes the same assertion with no argumentation but merely a reference to one unquoted journal article by Mark Karlberg.

Shepherd especially takes issue with the reformed idea that the works/merit principle plays a key role in the Mosaic covenant… According to reformed theology, the Mosaic covenant reminded Israel of the original condition of the covenant of works, namely, that God bound Adam’s posterity to perfect obedience as a condition of eternal life; therefore, in order to obtain eternal life, man must satisfy this condition, either by himself or by another.

All of this is flatly contradictory to the teaching of many Reformers and the actual doctrine of the Westminster Confession of Faith and Catechisms. The position being vilified is simply Reformed Orthodoxy in this matter.

In his section on the covenant, Zacharias Ursinus insists that the Mosaic Covenant and that of the Christian Church are substantially the same. Since there is “one way of reconciliation, one faith, and one way of salvation for all who are and have been saved from the beginning,” the covenants are “one in substance” (p. 98). Further, Ursinus explicitly addresses the issue of obligations:

There is but one covenant, because the principal conditions, which are called the substance of the covenant, are the same before and since the incarnation of Christ; for in each testament God promises to those that repent and believe, the remission of sin; whilst men bind themselves, on the other hand, to exercise faith in God, and to repent of their sins (p. 99; emphasis added).

Ursinus goes on to assert that the Old and New Covenants agree, “in the condition in respect to ourselves,” and explains that “in each covenant, God requires from men faith and obedience” (ibid; emphasis added). “The new covenant, therefore, agrees with the old in that which relates to the principle conditions, both on the part of God and on the part of man.” The benefits of these two covenants, incidentally, are “the remission of sins and eternal life” (ibid).

To remind readers of the limits of this essay, it is still conceivable that this Reformed position is wrong and it is logically possible that his dangerously so. Critics may offer arguments from Scripture if they wish to do so. But these arguments ought to admit the scope of their attack. It is the author of the Heidelberg Catechism of whose views our brother should write: “It is hard, then, to see why the New Covenant is so superior to the Old, or how it is founded on ‘better promises.’”

The Westminster Confession is quite explicit that the Mosaic Law was given as part of the Covenant of Grace. Chapter 7 is entitle “Of God’s Covenant with Man” so one would think that a comparison of Shepherd’s thought to that of the Westminster Divines would inspire some comment on that chapter from his critics. But, other than appealing to paragraph 2 and gratuitously inserting the concept of merit into the covenant of works, the silence is deafening. Here are paragraphs 2, 3, and 5:

The first covenant made with man was a covenant of works, wherein life was promised to Adam; and in him to his posterity, upon condition of perfect and personal obedience.

Man, by his fall, having made himself incapable of life by that covenant, the Lord was pleased to make a second, commonly called the covenant of grace; wherein he freely offereth unto sinners life and salvation by Jesus Christ; requiring of them faith in him, that they may be saved, and promising to give unto all those that are ordained unto eternal life his Holy Spirit, to make them willing, and able to believe.

This covenant was differently administered in the time of the law, and in the time of the gospel: under the law, it was administered by promises, prophecies, sacrifices, circumcision, the paschal lamb, and other types and ordinances delivered to the people of the Jews, all foresignifying Christ to come; which were, for that time, sufficient and efficacious, through the operation of the Spirit, to instruct and build up the elect in faith in the promised Messiah, by whom they had full remission of sins, and eternal salvation; and is called the old testament.

The Mosaic Covenant is an administration of the Covenant of Grace. It is noteworthy that many of Shepherd’s opponents want to insist that we are in the Abrahamic Covenant as an unconditional covenant of grace, in opposition to the Mosaic Covenant, which supposedly “is a covenant of works.” The Reformed view of the Westminster Confession is amply supported by the catechisms. Nowhere do they compare the covenantal status of believers to that of the Abrahamic covenant in contrast to that of the Mosaic. On the contrary, according to the Larger Catechism, the giving of the Decalogue on Mount Sinai is a type of the Gospel administration of the same covenant of grace.

Q101: What is the preface to the Ten Commandments?
The preface to the Ten Commandments is contained in these words, “I am the Lord thy God, which have brought thee out of the land of Egypt, out of the house of bondage.” Wherein God manifesteth his sovereignty, as being JEHOVAH, the eternal, immutable, and almighty God; having his being in and of himself, and giving being to all his words and works: and that he is a God in covenant, as with Israel of old, so with all his people; who, as he brought them out of their bondage in Egypt, so he delivers us from our spiritual thralldom; and that therefore we are bound to take him for our God alone, and to keep all his commandments (emphasis added).

The Shorter Catechism is, of course, shorter, but even more provocative in context. Compare question and answer #44 with #20 and #21:

What doth the preface to the Ten Commandments teach us?
The preface to the Ten Commandments teacheth us, That because God is The Lord, and our God, and Redeemer, therefore we are bound to keep all His commandments.

Did God leave all mankind to perish in the estate of sin and misery?
God having, out of his mere good pleasure, from all eternity, elected some to everlasting life, did enter into a covenant of grace, to deliver them out of the estate of sin and misery, and to bring them into an estate of salvation by a Redeemer.

Who is the Redeemer of God’s elect?
The only Redeemer of God’s elect is the Lord Jesus Christ, who, being the eternal Son of God, became man, and so was, and continueth to be, God and man in two distinct natures, and one person, for ever (emphasis added).

The Mosaic Covenant is not a covenant of works, but rather a type of the Gospel covenant and the same in substance with it as an administration of the covenant of grace. The Ten Commandments promise God as our redeemer. The Decalogue did not tell the Israelites to obey the law sinlessly in order to inherit life, much less to merit life by their obedience. Rather, it told them they were chosen by God to be delivered from misery and brought into an estate of salvation. Because of this grace they were bound to obey God, trusting in Him alone as their redeemer.

Thus, the exposition of the Decalogue in both catechisms jumps back and forth between the Old and New Testaments. Pauline imperatives were never meant as a covenant of works, though they show us God’s perfect righteousness and our own sinfulness in contrast. The Decalogue is no less of the Covenant of Grace and, as with Paul, the indicatives precede the imperatives.


To summarize then, these criticisms on the Covenant of Works and Mosaic Covenant appear to be a revisionist attempt to stamp out a major, and perhaps the majority, view of the Covenant of Works and the Mosaic Covenant within the Reformed Tradition. The accusation that there is confusion of Law and Gospel is a straightforward denial of the Reformed doctrine that both Law and Gospel are administrations of one covenant of grace, that both are conditional, and that they contain essentially the same conditions for the inheritance of resurrection glory.

Of course, the Reformed Tradition allows a number of views on these matters. While I want to fulfill my ministry by teaching what I regard as the pure Word of God, I also want to allow for the original diversity of the Westminster Assembly. Within my own denomination, the Presbyterian Church in America, I want to uphold what what Tim Keller has called “the original PCA contract.” But this consensus is not going to last if it is permissible to make heresy accusations against people who read and love Zacharias Ursinus and Francis Turretin. No house divided against itself can stand and no denomination will survive when the church courts are ignored while the internet fills with unproven allegations that others are “aberrant” or “miscreants” or worse. I certainly think there are any number of pastoral abuses that can occur with this teaching (as with any teaching), and I think any discussion of how to only promote the pastoral blessings would be a valuable conversation. But first we need to talk to one another.

May God give us his wisdom, which is peaceable.

Copyright © 2005

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