Did Jesus Require Baptism?

Jesus's ministry included baptizing: "After this, Jesus and his disciples went into the region of Judea, where he spent some time with them baptizing." (John 3:22.)

Is submission to baptism important? Could it be a requirement to be saved in John 3:5? I have assumed for a long time that because of the thief on the cross that baptism is quite optional. But I am beginning to think it has more importance than I have assumed for a long time.

In fact, I have been so saturated with Paulinist thinking for so long that even after becoming Jesus-centric, I still believed giving any importance to water baptism for salvation was simply crazy due to Pauline doctrine. However, someone recently challenged me on this, and so I studied more carefully the issue.

First, I realized that it is not as crazy an idea as it at first appears. Lutheranism for a long time has taught water baptism is essential for salvation, and thus  "baptism is ordinarily necessary for salvation." (The Lutheran Encyclopedia (Scribner 1899) at 40.) Luther found a way to insist upon it despite Paul's faith alone gospel. Luther claimed Paul does not exclude baptism as a work for salvation because it is supposedly not our work, but God's work. Luther said: "Yes, it is true that our works are of no use for salvation. Baptism, however, is not our work but God's," and God's works have saving power and are "necessary for salvation." (Jack Cotrell , Baptism: A Biblical Study (1989) at 140; Luther, The Larger Catechism (2008) at 100.)

Baptism in water would be important if Jesus means "baptism" by "water" in John 3:5 which says:

Jesus answered, "I tell you the truth, no one can enter the kingdom of God unless he is born of water and the Spirit." (NIV)

I have long thought this meant "born of water" at child birth.

But could water baptism with repentance have been intended by Jesus to represent the new birth?

In other words, did the new birth mean in fact to initiate by water and spirit simultaneously effectuating such a change? Did it mean by "water" in fact "water" and hence baptism? Is this why "the fathers from Justin Martyr downwards and every liturgy of Christendom unhesitatingly apply these words [in John 3:5] to Baptism, without allusion to any alternative interpretation" (Sir William Smith, A Dictionary of the Bible (1893) at I: 347)?

The Language of John 3:5 That Points To Water Baptism

In John 3:5, the Greek is "ex" water and spirit. "Ex" means "from," in the sense of either "away" or "source." Here the source-sense is in view. (Jack Cotrell , Baptism: A Biblical Study (1989) at 38.) The conjunction of "water and spirit" with a single verb signify they "together form a single means of that regeneration which is a prerequisite for entrance into the kingdom of God...." (Id.)

However, there are many modern authorities who argue, based on John 3:6, that Jesus meant by water being born of the flesh, i.e., natural birth. The next verse reads:

Flesh gives birth to flesh, but the Spirit gives birth to spirit.

Hence, this contention claims a paralellism between "born of water" in 3:5 which supposedly parallels "birth to the flesh" in 3:6, just as "born of...the Spirit" in 3:5 parallels "birth to the spirit" in 3:6. But this conclusion relies upon assuming water in 3:5 equates to birth in the flesh in 3:6. There might not be a parallelism at all; verse 5 could mean that the new birth is by water and the spirit, and verse 6 could simply mean flesh gives birth to flesh and spirit to spirit. There may be no clear parallelism except by a presupposition that links "water" to "flesh."

Others claim that "water and spirit" mean simply the spirit. Calvin wrote: "By 'water and Spirit,' therefore I simply understand the Spirit, which is water." (Calvin, Institutes 4.16.25 - Vol. 3 at 404.)

But this is silly, as it simply erases the word "water" without any justification. Jesus said the new birth was by "water," as distinct from the "spirit," as well as by the "spirit." Calvin simply affirms how he wishes the passage read, and does not give any rationale to erase the fact that two (not one) operative factors are involved: water and spirit.

Sir William Smith (1813-1893) in A Dictionary of the Bible (1893) at I: 347 correctly responds to the view that "water" meant "spirit" as Calvin claimed:

This not only contradicts the unanimous opinion of the Church, but does violence to the language of Holy Scripture. No one intending to convey the idea that the " water" was figurative would mention it before "the Spirit," and connect the two as parallel elements of birth. The being "born of water and the Spirit" is plainly one operation, wrought by two distinct, yet inseparable, means.

Tradition of Apostles and Early Church

Here is where tradition can help answer the question and help remove doubt. Research suggests that no theologian prior to 1600 ever believed "water" in John 3:5 meant natural child birth. Instead, the early apostles and church writers exclusively thought it meant baptism by water which was salvific when combined with repentance from sins:

Acts 2:38 - Repent and be baptized for the remission of sins.

Peter replied, "Repent and be baptized, every one of you, in the name of Jesus Christ for the forgiveness of your sins. And you will receive the gift of the Holy Spirit."

Acts 22:16 - Be baptized and wash away your sins.

"And now what are you waiting for? Get up, be baptized and wash your sins away, calling on his name."

Peter in 1 Peter 3:21

Corresponding to that, baptism now saves you—not the removal of dirt from the flesh, but an appeal to God for a good conscience—through the resurrection of Jesus Christ,

[This demonstrates that water alone does not save you, but it must be conjoined with repentance -- an appeal to God in a good conscience. But Paulinists try to redefine baptism in this verse to mean essentially a change of heart analogous to faith (Hovey: 421). Yet, such a view is not exposition, but a reconstruction of passages to read as one prefers.]

Even Paul had a passage that supports baptismal regeneration when combined with a word of confession:

(25) Christ loved the church and gave himself up for her to make her holy, cleansing her by the washing with water through [Greek en] the word [or command -the Greek 'remati.'] (Eph. 5:25-26.)

Watson Mils in Acts and Pauline Writings (Mercer University Press, 1997) at 227 says "literally, this serves as a text for baptismal regeneration ...By the word (NRSV), translates en remati, literally "in a word." This may imply a baptismal confession of the name of Christ (cf. 1 Cor. 6:11)...."

The early commentators all concurred that John 3:5's reference to "water" meant water baptism. Here are the key early quotes:

Justin Martyr, ca. 165 AD

"I shall now lay before you the manner of our dedicating ourselves to God through Christ on conversion. As many are therefore persuaded and believe that the things taught and said by us our true, and moreover take upon themselves to live accordingly, are taught to pray and ask God with fasting for forgiveness of their former sins, we praying together, and fasting for and with them, and then, and not till then, they are brought to a place of water and there regenerated after the same manner as ourselves, for they are washed...for Christ has said: 'Unless you are born again, you cannot enter the kingdom of heaven." [Quoting John 3:3, 5.]  (Justin, First Apology LXXIX at page 73-74.)

Irenaeus, 190 AD

"‘And [Naaman] dipped himself . . . seven times in the Jordan’ [2 Kgs. 5:14]. It was not for nothing that Naaman of old, when suffering from leprosy, was purified upon his being baptized, but [this served] as an indication to us. For as we are lepers in sin, we are made clean, by means of the sacred water and the invocation of the Lord, from our old transgressions, being spiritually regenerated as newborn babes, even as the Lord has declared: ‘Except a man be born again through water and the Spirit, he shall not enter into the kingdom of heaven’" (Fragment 34 [A.D. 190]).

Hippolytus, 217 AD

"[P]erhaps someone will ask, ‘What does it conduce unto piety to be baptized?’ In the first place, that you may do what has seemed good to God; in the next place, being born again by water unto God so that you change your first birth, which was from concupiscence, and are able to attain salvation, which would otherwise be impossible. For thus the [prophet] has sworn to us: ‘Amen, I say to you, unless you are born again with living water, into the name of the Father, Son, and Holy Spirit, you shall not enter into the kingdom of heaven.’ Therefore, fly to the water, for this alone can extinguish the fire. He who will not come to the water still carries around with him the spirit of insanity for the sake of which he will not come to the living water for his own salvation" (Homilies 11:26 [A.D. 217]).

Basil the Great, 375 AD

"This then is what it means to be ‘born again of water and Spirit’: Just as our dying is effected in the water, our living is wrought through the Spirit. In three immersions and an equal number of invocations the great mystery of baptism is completed in such a way that the type of death may be shown figuratively, and that by the handing on of divine knowledge the souls of the baptized may be illuminated. If, therefore, there is any grace in the water, it is not from the nature of water, but from the Spirit’s presence there" (The Holy Spirit 15:35 [A.D. 375]).

Abraham, 387 AD

"The Church was redeemed at the price of Christ’s blood. Jew or Greek, it makes no difference; but if he has believed, he must circumcise himself from his sins so that he can be saved . . . for no one ascends into the kingdom of heaven except through the sacrament of baptism. . . . ‘Unless a man be born again of water and the Holy Spirit, he cannot enter the kingdom of God’" (Abraham 2:11:79–84 [A.D. 387]).

"This Day I Have Begotten Thee" At A Water Baptism

Jesus's baptism may have been a type for us to follow, further demonstrating the point that water baptism is what regenerates us as children of God, i.e., makes us born again.

First, Jesus's own baptism involved the conjunction of water and the descent of the Holy Spirit. (Matt. 3:16.) Thus, Jesus's reference to "water and spirit" in John 3:5 would naturally draw one's mind to the experience Jesus had. It would be what we would naturally think is the purpose of Jesus water-baptizing in John 3:22 -- mentioned just 17 verses after John 3:5.

Second, in the original version of the baptism account of Jesus by John the Baptist, it involved a new birth --- where the Father said to Jesus "this day I have begotten thee." (Jesus was born as the unique Son of God, so His baptism is not completely analogous to our own.)

The baptismal account of Jesus in Luke 3:22 originally and in Matthew had this account that the Father spoke from heaven to Jesus: "This day I have begotten you." (Link.)

The original baptism language of "this day I have begotten thee" is also quoted in the NT in Hebrews 1:5 and 5:5.

Moreover, this original version of Christ's baptismal account -- where the Father says "this day I have begotten thee" -- was quoted pre-325 AD also by Clement, Methodius, Lactantius, in the Acts of Peter and Paul, and by Origen and Justin. See our full discussion at this link.

Epiphanius in the early 300s quotes the original version of Matthew in Hebrew as similarly saying:

And as Jesus came up from the water, Heaven was opened, and He saw the Holy Spirit descend in the form of a dove and enter into Him. And a voice from Heaven said, ‘You are my beloved Son; with You I am well pleased.’ And again, ‘Today I have begotten You.’ “Immediately a great light shone around the place; and John, seeing it, said to Him, ‘Who are you, Lord? And again a voice from Heaven said, ‘This is my beloved Son, with whom I am well pleased.’ Then John, falling down before Him, said, ‘I beseech You, Lord, baptize me!’ But He forbade him saying, ‘Let it be so; for thus it is fitting that all things be fulfilled.’” (Epiphanius, Panarion 30.13.7, quoting the Hebrew Matthew.) [Wikipedia]

It was only post 325 A.D. that the standard texts of Matthew and Luke were revised to omit "today I have begotten thee" from Jesus's baptism by John-the-Baptist. You will not find it any longer in the KJV, ASV, NIV, etc. This was because of the controversy with Arius in 306 A.D. who claimed the 'begotten' passages meant Jesus was not the "Eternal Son of God." However, the Roman Catholic church by 325 A.D. felt it was imperative to assert this about Jesus even though no verse in the NT ever calls Jesus the 'eternal Son of God.' For background, see Wayne A. Grudem, Systematic theology: an introduction to biblical doctrine (Zondervan, 1994) at 243. Hence, words from the original account were let slip in reproductions, to the point we do not any longer see them in our NT.

Hence, at Jesus's water baptism, God-the-Father gave Jesus a new birth as Son of God (a unique status), declaring from heaven "This day I have begotten thee." This was an example of how baptism would have similar effects on ourselves although obviously we would not become Divine as Jesus uniquely was indwelled by the Father/Word. (John 1:1, 14:10.)

Typical Paulinist Disagreement That Baptism Is Needed

Of course, Jesus said baptism was a work of righteousness (Matt. 3:13-15). If one accepts Paul as valid, such an act of righteousness never could be necessary for salvation -- as Paul is generally interpreted to affirm. (Eph. 2:8-9.) Baptism might be a fruit of faith, but Paul would never tolerate it as a conditional requirement for salvation, so Paul is understood to say. For example, Paul speaks apparently specifically to that point in Titus:

Not by works of righteousness which we have done, but according to his mercy he saved us, by the washing of regeneration, and renewing of the Holy Ghost...Titus 3:5

Here Paulinists say Paul believes the only washing necessary for rebirth is of the Holy Spirit to save us. No act of righteousness can do so - an allusion to baptism which Jesus called an act of "righteousness" to John the Baptist when Jesus submitted to baptism (Matt: 3:13-15).

However, and very ironically, Hovey, a Pauline thinker, confesses Paul likely means in Titus 3:5 by "saved...by washing of regeneration" that we are saved by water baptism, as Paul's Greek actually means the' washing of the laver/water basin of regeneration.' But Hovey escapes that literal meaning by interpreting Paul to have meant that water baptism is figurative/symbolic, and not causative. Hovey: 422.

Putting aside whether Titus 3:5 is yet another verse proving the importance of water baptism, Walvoord claims any view that "born of water" in John 3:5 signifies baptism (as a concurrent means of the 'new birth) would contradict Paul and thus cannot be true:

"[One view of 3:5 is] the water refers to baptism as an essential part of regeneration. This view contradicts other Bible verses that make it clear salvation is by faith alone....Eph. 2:8-9; Titus 3:5." (John F. Walvoord, Roy B. Zuck, The Bible Knowledge Commentary: New Testament (1983) at 281.)

Hence, the standard refrain from modern Paulinists is that water baptism is a mere ceremony and is insignificant for salvation. For example:

But for now, the reason baptism is not necessary for salvation is because we are justified by faith (Rom. 5:1; Eph. 2:8), not by faith and a ceremony (Rom. 4:1-11).  You see, a religious ceremony is a set of activities or forms peformed by someone.  In the Bible circumcision was a ceremony where one person performed a religious rite on another person.  Likewise, baptism is also a ceremony where one person performs a religious rite on another person.  But, we are saved by faith alone and anything else we do, including ceremonies, will not help. (Christian Apologetics and Research Ministry.)

Even modern Baptists say baptism is not essential for salvation based upon Pauline principles:

To apply baptism for salvation, therefore, is making a false saviour of the ordinance. (The Baptist Manual (1849) at 64.)

Another Baptist publication stated in reliance on Pauline doctrine that baptism is not important for salvation:

[Scripture] cannot possibly imply that baptism is essential to salvation. Were this the case, then it would not always be necessarily true that faith is salvation. Were this true, it would imply that an external work performed by man is necessary to salvation. (Alexander Carson, Baptism in its mode and subjects (American Baptist Publication Society, 1860) at 477.)

But if Jesus means by "water" in John 3:5 the notion of baptism, then Jesus contradicts Paul (unless Titus 3:5 is in accord with Jesus). If so, an act of righteousness -- baptism -- does in part play a crucial role in salvation when baptism is physically possible for you to submit to.

Luther Said Baptism Was Crucial

Incidentally, as mentioned previously, Luther taught baptism was essential for salvation, and thus official Lutheranism still maintains that "baptism is ordinarily necessary for salvation." (The Lutheran Encyclopedia (Scribner 1899) at 40.)

Luther himself said baptism is ordinarily "necessary for salvation." (Jack Cotrell , Baptism: A Biblical Study (1989) at 140; Luther, The Larger Catechism (2008) at 100.)

First Divergence from Luther

The surprisingly universal consensus since inception of Christianity that baptism was essential to salvation (whether right or wrong) was first abandoned by Zwingli. This was the same pastor who removed every book from the New Testament but Paul's epistles and the book of Hebrews. (See our link on that issue.) Zwingli was an extreme Paulinist.

In 1523-1525 A.D. Zwingli "single-handedly created a new view of baptism that separated it from salvation." (William R. Baker, Evangelicalism and the Stone-Campbell movement (Intervarsity Press, 2002) Volume 1 at 84.)

Now most modern Protestants agree with Zwingli (and not with Luther) that baptism is completely optional, and failure to be baptized has utterly no impact on your salvation.

My Advice

Because John the Baptist, Jesus and the early apostles baptized those coming forward in repentance, it appears to imply a duty to submit to this process by those who call on Jesus for salvation. If Jesus made it a requirement in John 3:5, then of course we must obey.

Can one be saved without baptism in water? It appears the thief on the cross had no baptism after his conversion, yet Jesus promises that day he will be in paradise with Jesus. This would imply sometimes salvation is not dependent on baptism. However, some who insist baptism is always necessary claim this example is inconclusive for one cannot be sure the thief was not previously baptized. (See this link.)

However, I would conclude that if one comes to repentance and faith just before death, God has power to save anyway as obedience to baptism was not time-wise possible. However, if it is time-wise possible, we should submit to this command. Deliberate disobedience to baptism apparently would risk one's salvation.

FURTHER READING

In whose name were we supposed to Baptize? The name of the Lord Jesus - Yahshua. A very late addition to Matthew 28:19 purported to have Jesus endorse using three names. However, this was a false addition scribbled into the Bible at sometime after the Nicene Council in 325 A.D. For proof, see this link.

Infant-Baptism: Calvinists like Catholics Treat Infant Baptism as Magic Unto Salvation in Reliance Upon Paul. 

The truth is children are spiritually safe until they reach the age of accountability, and sin.

Long ago, the prophet Ezekiel stated unequivocally, after contrasting the behavior of a father with his son, that there is no inherited sin (from Adam or anyone else): “The soul who sins shall die. The son shall not bear the guilt of the father, nor the father bear the guilt of the son” (18:20; cf. vss. 2-19). (This is why the Eastern Orthodox for centuries rejected Paul's doctrine of inherited sin.) You start pure and at some point you sin: “You were perfect in your ways from the day you were created, till iniquity was found in you” (Ezekiel 28:15).

Jesus, Himself, demonstrated the spiritually safe condition of children when He stated: “Assuredly, I say to you, unless you are converted and become as little children, you will by no means enter the kingdom of heaven” (Matthew 18:3). Adults must become like children if they wish to be saved! Children hardly can be spiritually depraved! Christ followed up this declaration with a comparable observation: “Let the little children come to Me, and do not forbid them; for of such is the kingdom of heaven” (Matthew 19:14).

Jesus wants us to become all like children so we are spiritually safe. It logically follows children are spiritually safe.

However, in reliance primarily upon Paul's statement that children are sanctified through their parents (1 Cor. 7:14), the early Calvinist position was that infant baptism saves (or is a sign of salvation of being born to Christian parents). This is the identical view of Catholicism -- that a permanent seal of salvation and justification happens upon water baptism as an infant.

This is another example of why it is erroneous to rely upon Paul. Baptism becomes a magical right similar to pagan belief and practice. It is no different than indulgences -- a work by someone other than yourself that imparts salvation.

However, under the Jewish understanding of the Bible, children are not of age to be judged for sin, and thus are not hell-bound until they sin after becoming accountable. No fixed date is given in the Bible. Each parent should be able to discern when their child's sin is consciously done as an adult, and no longer as an innocent child.

Here are snippets of the Calvinist view from this link -- so akin to the Roman Catholic view -- citing primarily Paul in 1 Cor. 7:14. The fact Paul is the sole proof for this practice should be proof alone not to baptize your children until they are mature enough to be an adult who can pledge their faith and obedience to Christ. (I think age 15 is when I was capable of making adult decisions. It may vary depending upon the mental capacity of your child). So these snippets are:

John Knox
“The conviction of the writers of that Book of Common Order, was thus the Biblical perception that the children of believers are Christians already, before being baptized in their infancy.”

Genevan Book of Church Order, still describing covenant children, the Preface then continues: “They be contained under the name of God’s people…. Remission of sins in the blood of Christ Jesus doth appertain unto them by God’s promise…. Paul…pronounceth the children begotten and born (either of the parents being faithful) to be clean and holy. First Corinthians 7…. “The Holy Ghost assure us that infants be of the number of God’s people and that remission of sins doth also appertain to them in Christ…. 

Belgic Confession
“This signifies to us that as water washes away the filth of the body when poured upon it, and is seen on the body of the baptized when sprinkled upon him, so does the blood of Christ by the power of the Holy Ghost internally sprinkle the soul…by the sprinkling of the precious blood of the Son…. First Corinthians 6:11; Titus 3:5; Hebrews 9:14; First John 1:7; Revelation 1:6.”

Dr. G. de Bries (1608)
“One should note…to whom the sign of baptism applies. Holy Scripture clearly teaches us that it applies to the entire household of God; to the whole body of His congregation; that is, to all of those who are His people, both small and large…. Little children…have the sproutings of faith…. ….The little children are renewed by God’s Spirit according to the measure and comprehension of their age. And this divine power, which is hidden within them, grows and gradually increases….they are redeemed, sanctified and regenerated from perdition — even though natural corruption still remains in them. For they possess such regeneration not through their own goodness, but through the sole goodness and mercy of God in Jesus Christ.”
G. de Bries, The Radical Origin and Foundation of the Anabaptists, ed. 1608, Bk. III. Ib. f. 290a.

 Dr. Casper Oliveanus
“Thus, our children are holy — by way of the covenant of grace…. See First Corinthians 7:14 and Ezra 9:2…. The promise of the Gospel has been made expressly to our children, Deuteronomy 30:6…. God consummated internally that which He promises externally. Titus 3:3-8 ?Everlasting life is sealed by the testimony of the Holy Spirit and imparted by the Holy Spirit.” Casper Olevianus, The Essence of the Covenant of Grace. (Copinga’s translation, Groningen, 1739) at 497f.

The Second Helvetic Confession
“We condemn the Anabaptists, who deny that new-born infants of the faithful are to be baptized. For, according to evangelical teaching, of such is the Kingdom of God (Luke 18:16) — and they are written in the covenant of God (Acts 3:25)…. Why, then, should the sign of God’s covenant not be given to them? Why should those who belong to God…and are in God’s Church — not be initiated by holy baptism? We condemn the Anabaptists.” 
2nd Helv. Conf. chs. 11,19-22,30. “Damnamus Anabaptistas” (twice, in arts. 22 & 30). 83) Op. cit. p. 206. 84) Creeds I p. 644.

Dr. Theodore Beza
“The Anabaptists greatly err by opposing the baptism of infants…. Although they may not have faith with its effects such as those who are of age — they may, however, have the seed and germ of it; seeing that the Lord has sanctified them from the mother’s womb (First Corinthians 7:14)…. We presuppose in general that they are children of God — who are born of a believing father and mother, or when one of the two is a believer (Genesis 17:7).” Further, “as regards children born in the Church, one should presume the election of all of them, without limitation.”
Dr. Theodore Beza, The Christian Faith (1558)

Decrees of Dordt I:17.
Second. such elect ones also include many babies. For Dordt insisted that “the children of believers are holy not by nature but by virtue of the covenant of grace in which they, together with the parents, are comprehended. Godly parents have no reason to doubt the election and salvation of those their children whom it pleases God to call out of this life in their infancy. First Corinthians 7:14; Genesis 17:7; Isaiah 59:21; Acts 2:39.”
Vander Waal’s, p. 53. Comp. too Gravemeijer: III:20:22 p. 139.

Dr. John Calvin
“Let him (Heshusius) then accuse Paul of blasphemy — for saying that Christ is formed in us like the foetus in the womb. His well-known words to the Galatians are: ‘My little children, for whom I again travail, as in birth — until Christ Jesus be formed in you.’ Galatians 4:9….”

“God therefore calls those who were thus slain — ‘His sons.’ Just as if a husband should reproach his wife with depriving him of their common children…. Children are more precious than all goods…. A father is more grievously injured, if children are taken away…. God here pronounces…’you have born them — unto Me.’”

“The Jews were naturally accursed, through being Adam’s seed. But by supernatural and singular privilege, they were exempt and free from the curse — since
circumcision was a testimony of the adoption by which God had consecrated them to Himself. Hence, they were holy…. As to their being impure, it could not…abolish God’s covenant…. And so Paul says that the children of the faithful are holy — since baptism does not lose its efficacy, and the adoption of God remains fixed. First Corinthians 7:14.”
Calvin’s True Partaking of the Flesh and Blood of Christ in the Holy Supper, in his Tracts & Treat. II pp. 497f. 306) Ib. pp. 534f.

Dutch Calvinist Cornelius Poudroyen
Believers’ children “have the Holy Spirit and the redemption from sin — just as the adults do.” “First Corinthians 7:14 — ‘Otherwise your children would be unclean; but now, they are holy.’” “”¦one cannot be holy, without the Holy Spirit…. Children have faith.”

Dr. Herman Bavinck
“Calvin says…that the children of believers are already holy even before baptism through a supranatural grace (Institutes IV:16:31)[paraphrase from 1 Cor. 7:14]; that the seed of faith and conversion hides within them through a secret operation of the Spirit (IV:16:20); that they partake of the grace of regeneration by virtue of the promise; and that baptism follows by way of sign…. Men had this feeling that the regeneration of children took place before baptism….” Herman Bavinck: Reformed Dogmatics I p. 29 & n. 1, and III pp. 266f (as cited in Wielenga’s op. cit. pp. 241f).