PC088Antithesis 1:2 (March-April, 1990) Covenant Media Foundation, 800/553-3938

Issue and Interchange: Does Scripture Permit the Use of Hymns Other Than the Psalms in Worship? [Hymns allowed position]
By Dr. Greg Bahnsen


The goal of this regular feature is to provide our readers with opposing arguments on topics pertinent to the Christian life. Due to the power of party spirit, personal credibility, credentials, etc., we have asked all the authors writing for this feature to publish their brief statements anonymously. By doing this, we hope to encourage the reader, in some small way, to focus on the arguments involved in each position rather than on personal factors.

The authors selected for the respective sides in the debate have published and/or lectured in defense of their theses.

The burden of proof in the interchange is placed on Advocate One. For that reason, Advocate One opens and closes the debate.

Issue: Does Scripture Permit The Use Of Hymns Other Than Psalms In Worship?

Advocate 1: Scripture Does Permit the Use of Hymns Other Than Psalms in Worship

There are two really admirable points about those who hold to exclusive psalmody. (1) They make our commitment to the "regulative principle of worship" very clear. I adhere staunchly to that principle and increasingly see the need for it to be stressed in the church atmosphere of our age. (2) Exclusive psalm-singers remind us of the surpassing value of singing from this portion of God's word. Many churches miss the rich blessing that can come from this practice.

Nevertheless, to prohibit congregational singing of anything but the Old Testament psalms is an unwarranted addition to the word of God (cf. Deut.4:2) and - ironically - a violation of the regulative principle of worship thereby. The crucial question is this: Where in Scripture does God restrict His people to singing only the songs in the book of Psalms? No such restriction can be demonstrated. Those who try to infer it end up relying on fallacious arguments. Those who insist that we must positively demonstrate that anything we sing has the explicit warrant of Scripture have misunderstood and misapplied the "regulative principle" - on a par with somebody who would hold that the very words of our prayers and sermons must have the explicit warrant of Scripture.

First, it is unreasonable to restrict singing to the 150 songs in the book of Psalms. These are not the only inspired songs in the Bible (e.g., the song of Moses, the magnificat of Mary, the psalms recorded outside the psalter). in Ezra 3:11 we read of the Levites singing words (after the time of the Psalter) which will not be found anywhere as such in the Psalms. David himself in the psalter said that God's people were to sing His "statues" and "all of His wondrous deeds." This takes us beyond the words of the Psalms!

Second, it is theologically deficient to restrict our praise to the old covenant anticipations of our Savior and His redemptive work. There is no question about the fact that Christ and His saving ministry are found in the words of the Psalms; praise the Lord for the Christology of that book! But it would be preposterous to think that the Christology and soteriology of the Psalms come anywhere close to the explicit, detailed, and clear teaching about Christ and salvation found after His incarnation and the actual accomplishment of redemption - the Christology and soteriology of Paul, John, and the rest of the New Testament. We are New Covenant believers; although being one the Old Testament people of God who enjoyed the same covenant of grace as we do, we enjoy a fuller revelation and better administration of the covenant than they did. Our worship and praise for God's deliverance should reflect that progress.

Third, it is erroneous to think of singing as a separate element of worship. Singing is rather just one of the many legitimate means of pursuing the various elements of worship. Prayer, praise, exhortation, and teaching are among the proper elements of worship (as regulated and restricted by the word of God). But all of these can be pursued by various means: meditation (e.g., silent prayer, reflection on Scripture), plain speech (e.g. praying aloud, preaching a sermon), OR in song (i.e., with increased melody and rhythm). Singing, you see, in just one of the ways in which we pray, or praise, or exhort, or teach one another.

Notice how Col.3:16 categorizes "psalms, hymns, and spiritual songs" as forms of teaching and admonition; this is one of the Biblically defined functions of song in worship (cf. I Chron. 25:1; I Chron 14:15, 26). Therefore, since it is not a separate element of worship, singing does not require a separate Biblical justification.

Fourth, it makes little sense to say that the words of our songs must come directly from the Bible (or psalms), when one does not likewise restrict the words of our sermons to what is directly found in the Bible! Both are forms of teaching and admonition. What reason could there be for holding that teaching-in-plain-voice may use words outside the Bible, but teaching-in-song may not use words outside the Bible? (E.g., I can say "A mighty fortress is our God" in a sermon, but we cannot add melody and sing the very same words!) Teaching is not identical with reading from Scripture (I Tim. 4:13) - whether in song or not.

Finally, the exegesis of exclusive-psalm-singers is not acceptable at Colossians 3:16 and Ephesians 5:19. If these verses are referring to more than the songs of the book of Psalms, then it is acceptable for Christians to sing more than the songs from Psalms. Exclusive-psalm-singers must argue, then, that the words "psalms, hymns, and spiritual songs" in these verses all apply to the Psalms and can be applied to nothing but the Psalms. That is clearly mistaken, however. 2 Samuel 22 is not part of the book of Psalms, but it is called a "psalm" in verse 1; the new revelation of 1 Cor. 14:26 is obviously not from Psalms, but it is called a "psalm." Or take the word "hymn." Can this word (in itself) apply to compositions other than the those from the book of Psalms? Obviously, yes. Well then, is there anything about this word in the context of Col. 3 or Eph. 5 to restrict its referent to the book of Psalms? Not at all. Finally, exclusive-psalm-singers must argue that "spiritual song" must mean "inspired song" (thus being restricted to the words of Scripture for us). But the word "spiritual" does not mean the same thing as "inspired," as is clear from its use in 1 Cor. 2:15; 3:1; and Eph. 6:12. So then, "psalms, hymns, and spiritual songs" does indeed apply to the Psalms, but it is mistaken to argue that such words can apply only to the Psalms. (Likewise, the fact that "apostolic letters" can apply to the epistles of Paul does not prove that the expression applies only to Paul's letters!)

Therefore, I believe that the exclusive-psalm-singers do not rest the case for their position solely on Scripture. they cannot demonstrate that God prohibits singing anything but the Psalms in worship or that singing non-Psalms violates the regulative principle (any more than preaching words not recorded in Scripture). Their arguments are flawed by fallacious reasoning and exegetical mistakes. The persuasiveness of their position does not rest on Biblical authority, then, but rather on church tradition and subjective personal considerations (e.g., emotional attachment to the Psalms, which is quite understandable). It is not Reformed to allow such matters to control or restrict our worship.

Advocate 2: Scripture Warrants Only the Singing of Inspired Hymns

Awareness of the importance of the Regulative Principle is a wholesome sign. Yet it is possible for a profession of allegiance to this principle to be vitiated by self-deception. A good beginning may be hedged about by the spurious claim that Christian liberty under the New Testament leaves open an area in which the Church may institute modes of worship. Or illicit applications may be made, by which it becomes evident that the principle has not been understood. What has been stated as the crucial question is an instance of such misunderstanding. This question presupposes that the Psalm-singer is obliged to show that Scripture contains explicit prohibition of the singing of songs other than the Psalms. This demand by the Hymn-singer is an instance of the lax principle of the Lutherans and Anglicans that only what is explicitly forbidden in the Scripture is to be excluded from worship, while the Reformed principle states that worship which is not prescribed in the Word is a violation of the Second commandment. Consequently, the burden of proof is on the Hymn-singer to show that there is Scriptural warrant for singing of uninspired songs in worship.

Defenders of non-Scripture hymns are fond of designating the opposed position by the ambiguous expression "exclusive Psalm singing." Many who adhere to this view, like the late Professor John Murray, have granted the propriety of the use of versions of other Scripture songs. The present paper defends only the propositions: (1) Scripture warrants the singing of the 150 Psalms, and (2) Scripture does not warrant the singing of uninspired hymns. The singing of other Scripture songs in worship will be neither defended nor opposed. This policy renders a number of the opposing arguments irrelevant to the question whether the introduction of uninspired hymns can plead Biblical warrant.

The attempted plea rests partly on general grounds and partly on specifically exegetical considerations. A chief example of the former is the analogy of singing with prayer and preaching. It should be observed first that logic teaches us that arguments from analogy are at best inconclusive and at worst illusory. The argument in question is a case of the latter sort, particularly in the case of preaching. Preaching is addressed to sinful man; praise is addressed to the Holy Sovereign God. Instruction is only incidental to the singing of praises and not the essential characteristic of this element of worship. This consideration should banish the sophistry of pretending that singing God's praise is not an element of worship. Even the didactic Psalms are fundamentally in praise of God, whether the central theme is the confession of sin, Ps. 32, or the faithfulness of God notwithstanding the repeated idolatry of the visible church, Ps. 78. The misapplication of Col. 3:16 in this matter, leading to the conclusion, "singing does not require a separate Biblical justification," means the emancipation of singing in worship from the Regulative Principle which has clearly not been understood. A sinister practical effect of this attitude is that, instead of being determined by God's Word, what is sung in worship becomes a matter of making concessions among various conflicting groups in much of the professing church. Thus, it is the will of man which decides what is to be sung in God's praise.

The Christological or Dispensational argument may also be classified as general, although it involves some exegetical considerations. First, the concession is made that Christ is found in the Psalms. Then the consequences are denied. Far from it being preposterous, it is a striking fact that the inner sufferings of the Saviour's soul are set forth more fully in the Psalms, like the twenty-second and the sixty-ninth, than in any historical or doctrinal passages of the New Testament. The inference that the Psalms are insufficient in containing the content of song for the New Testament is the kind of fallacy commonly found in Dispensational arguments.

Space allows only a few exegetical remarks which may be supported elsewhere (as in Mike Bushell's excellent work) by detailed argument. Ezra 3:11 plainly refers to Ps. 106:1 and obviously does not claim to be the entire Psalm. II Samuel 22 is definitely Ps. 18 with minor verbal alterations in places. In I Cor. 14:21 the natural meaning of psalmos is an Old Testament Psalm which may have been selected charismatically. In any case, if it were charismatic in content, it was an inspired song. Similarly, it is not necessary to settle many disputed questions in Eph. 5:19 and Col. 3:16 to realize that they offer not the least warrant for uninspired hymns and songs in public worship. They may only prescribe rules for informal conduct of Christians. As for -pneumatikos, Eph. 6:12 is the only passage where it refers to creatures rather than the Holy Spirit and His special work. To support hymns from a series of "maybes" is to commit the fallacy of arguing from possibility to actuality. And the possibility itself is no more than, "I don't know that it isn't so."

The concluding paragraph of Advocate One's paper contains serious charges and has a tone other than the irenic expressions of the opening paragraph. Propositions one and two are both established by appealing to Scripture: first that Scripture commands the singing of Psalms, which is granted by Advocate One, and secondly, that Scripture nowhere warrants humanly composed songs in public worship. There is a temptation to make counter-charges, to assert, "The arguments of hymn-singers are flawed by fallacious reasoning and exegetical mistakes." The observation may be made that even when they give lip-service to the Regulative Principle, they are in fact influenced by the current practice in their own churches, far removed from that of the Westminster Assembly, not to speak of Calvin, Augustine, and first of all the Apostolic church. An appeal to tradition of this sort is simply a justification of the right to be called Reformed or Calvinistic, while Scripture remains the sole infallible rule of faith and practice. But apart from such reflections, let the argument speak for itself.

Advocate 1 Response

If Advocate 2 would sincerely seek to be irenic, he should refrain from accusing those who disagree with him of not adhering to the Reformed regulative principle of worship[1] (giving it only "lip-service") and psychologizing their motives (which he has no way of knowing) as influenced instead by current practices in the church. Advocate 2 wishes to eschew talk of fallacious reasoning.[2] He would rather just think that those who disagree with him do so because they are unaware of, or do not understand, or do not honor the regulative principle. That is simplistic, as well as erroneous. And it has unnecessarily disrupted the peace of Christ's church.

As a step toward restoring that peace, let us grant that both of us are committed to the regulative principle, but disagree in its application.[3] The regulative principle does not require that every particular thing done in connection with worship be warranted by Scripture (e.g., "circumstances" such as sitting in a pew, starting at 11:00 A.M., wearing a tie), but that every "element" of worship as such - everything invested with liturgical significance (e.g. Romanist elevation of the communion tray) - requires Scriptural justification. Is singing a separate "element" of worship or a "circumstance" of worship? If the latter, it does not require Biblical warrant according to the regulative principle.[4] I have argued that singing is simply one means to (one circumstance through which to) pray, praise, exhort or teach - rather than an element of worship itself. I proved this from Colossians 3:16, where singing is a form of instruction. Advocate 2 missed the point by replying (dubiously) that instruction is "only incidental" because praise is the "essential characteristic" of singing.[5] But my argument remains. Praise may be given to God in plain voice (during prayer, preaching or testimony) as well as in song. Why would it be acceptable to praise God in a sermon with words outside of Scripture, but unacceptable to do so when melody is added to those very same words and the congregation sings them?[6]

To this Advocate 2 has no answer whatsoever - beyond calling it "sophistry" and alleging it to have a "sinister practical effect."[7] Until he refutes the claim, we should conclude that singing uninspired hymns no more violates the regulative principle than does preaching or praising or exhorting with uninspired words.

Now let me address a few incidental points in Advocate 2's reply. (1) Is it really "Dispensationalism" to argue that New Covenant worshippers have a fuller revelation and better administration of the covenant of grace than Old Covenant worshippers? See the Westminster Confession of Faith VII.5-6. It was not penned by dispensationalists. New Covenant worship should reflect the progress of redemptive history and revelation.

(2) Does Scripture warrant the singing of uninspired hymns in New Covenant worship? Advocate 2 says "no," claiming "Scripture nowhere warrants humanly composed songs in public worship."[8] But I believe Colossians 3:16 and Ephesians 5:19 give that very warrant - referring to "psalms, hymns and spiritual songs" (not "psalms, psalms and psalms"). Advocate 2 attempts to dismiss this Biblical evidence by claiming that it "may only"[9] pertain to informal conduct of Christians," rather than to public worship. It would be natural to suppose that when Paul speaks of believers singing with grace in their hearts and admonishing one another with hymns, he is referring to believers gathered together and engaged in worship. (How often do we sing to each other as part of informal hospitality?) On what basis does Advocate 2 say otherwise and restrict Paul's referent to activity outside of congregational worship? Arbitrariness is not a convenience the theologian may indulge.

(3) Advocate 2's response continues certain exegetical mistakes. The words of praise in Ezra 3:11 are not identical (no more, no less) with Psalm 106:1. Even Advocate 2 admits that II Samuel 22 is not identical with Psalm 18, noting the verbal alterations. The "natural" meaning of I Corinthians 14:26 is not that an Old Testament psalm has been charismatically selected; this is not natural, but stems from a theological preconception. The content of the "psalm" is given by the Spirit, just as in the case of the "teaching, revelation, or tongue" which are mentioned right along side of it. Finally, regarding Colossians 3:16 and Ephesians 5:19, Advocate 2 concedes that "spiritual" song need not, given Scriptural usage elsewhere, denote the special work of the Holy Spirit (inspiration) - in which case his conclusion about singing in worship rests upon an insufficiently supported personal preference (an unwitting departure from the regulative principle).

Advocate 2 Response

The abusive personal attack in the opening paragraph of Advocate 1's response is best ignored. "Advocate 1" is in this response used to designate the written text and not the writer. It is in this sense that Advocate 1 fails to adhere consistently to the regulative principle by applying it in a way that nullifies it. No charge of insincerity is made against the person who proposes the principle. Application may be more or less far reaching. To apply a principle in a way that defeats its genuine tendency is to reject the principle in fact while asserting it in words. When the regulative principle is made to support such innovations as dance, rock music, and a host of other forms of false worship, it is clear that the principle has not been meant in its proper sense.

Advocate 1 is unclear as the nature of circumstances in public worship. The Westminster Confession, Ch. 1, Sec. 6 speaks of "some circumstances...common to human actions and societies." The Lutheran and Anglican view involves such a confusion of these circumstances with elements of worship as Advocate 1 falls into. Singing God's praise is not a circumstance common to human actions and societies. It is rather the element of worship that directly declares the glory of God in a way not done by prayer, which expresses the desires of men, and by preaching, which is addressed to men. The use of the same words in a sermon and in a hymn is radically different. The former is instruction to man directly and praise to God incidentally. The latter is praise to God directly and instruction secondarily. The Reformed faith surely does not endorse the view widely practiced in Evangelical circles, that a major purpose of Gospel hymns is evangelism.

Colossians 3:16 does not subordinate singing God's praise to instruction in doctrine in such a way, or in the less extreme, but none the less erroneous way asserted by Advocate 1. The answer to which Advocate 1 is blind has already been given in the preceding paper, and has been developed in this paragraph.

There is an anomalous feature of the tactics of Advocate 1. First, the content of sung praise is held not to "require Biblical warrant according to the regulative principle." Later we read "I believe Colossians 3:16 and Ephesians 5:19 give that very warrant." These two positions can be rendered logically consistent only by sacrificing any claim to a unified defense of uninspired hymns in worship. That the two texts may only refer to informal practice is no part of the positive argument for singing the Psalms or hymns found in the Bible. This consideration is only meant to eliminate the claim that the text provides warrant for uninspired hymns in worship.

The argument from possibility to actuality is an elementary logical fallacy. But the argument from possibility of not p' to the denial of the assertion of the necessity of p' is strictly valid. This is what is the case when from the possibility of the text's not meaning that certain songs may be sung in worship, there follows the denial that the Regulative principle warrants (i.e. implies the necessity of) the allowability of the practice.

The rejection of Dispensationalism obviously does not imply a refusal to use the language of the WCF Ch.7, Sec. 5-6. What was intended was that the position that asserts the unity of the Covenant of Grace in both dispensations and yet argues from differences to the lawfulness of uninspired hymns in worship may be paralleled by that of Reformed Baptists from the difference of the dispensations to the denial of infant baptism. This minor observation is subordinate to the major point that the Old Testament in general and the Psalms in particular exalt Christ as the eternal Son of God and as the only Mediator between God and man.

Advocate 1 Concluding Remarks

Advocate 2 argues that singing in worship must be restricted to inspired words (for instance, the psalms), and he wishes to draw this conclusion from the regulative principle of worship. In my past two essays I have tried to show that such reasoning is fallacious, being (1) inconsistently applied and (2) resting on a misunderstanding of the regulative principle itself.

What now does Advocate 2 reply? He simply asserts that the "genuine tendency" of the regulative principle really supports his view, not mine. That is, Advocate 2 openly begs the question that we are supposed to be debating. He just announces that "it is clear that the principle has not been meant in its proper sense" when made to support "forms of false worship," like singing uninspired hymns.[10] This is not an argument; it is merely repeating what you are supposed to prove. Previous essays give reason to believe that it is the theological tradition defended by Advocate 2 (one which is noble but narrow) which has misunderstood the proper sense of the regulative principle.

I have argued that singing is not an "element" of worship, but rather one "circumstance" by which we perform various elements of worship (praise, prayer, instruction, testimony). Advocate 2 disputes this in two ways.[11] First, he claims that singing[12] is "not a circumstance common to human actions and societies" - which is just false. Second, he claims that singing God's praise declares God's glory "in a way not done" by prayer or preaching.[13] What is this difference? He does not specify. What evidence does he offer? None. He is simply being arbitrary. He pronounces that "the use of the same words in a sermon and in a hymn is radically different." Then exactly what is that relevant difference? Moreover, what Scripture warrant is there for such an exaggeration? Advocate 2's opinion that a sermon is "directly" instruction, but only "incidentally" praise, is equally artificial.[14]

But this is still not the biggest mistake in his reasoning. Accept (for argument's sake) the artificial view that singing a psalm is "direct praise," while a sermon or prayer is "incidental praise." Advocate 2 does not tell us why our "incidental praise" (the sermon, prayer or what have you) may not be communicated through the medium of music - in the form of a hymn.[15] He has not noticed that his argument is senseless and unsuccessful unless singing in worship is restricted exclusively to direct praise - a view which is at odds with Paul himself (Col.3:16)!

Advocate 2 makes a weak and unpersuasive effort to make my defense of uninspired hymns out to be logically inconsistent. On the one hand I say that a Biblical warrant for singing uninspired words is not necessary; on the other hand, I say that such a warrant nevertheless can be found in Col.3:16 and Eph.5:19. Why Advocate 2 finds these remarks (involving, as they do, different modalities) logically inconsistent is a mystery. Imagine Bert arguing that the dish Julie brought to the church dinner is not "fruit salad" unless it includes peaches. It would be perfectly logical to reply both that (1)peaches are not"necessary" to fruit salad, but (2) even Bert should recognize Julie's dish as fruit salad because it just so happens to actually contain peaches anyway.

And it so happens that the New Testament includes (by example) uninspired hymns in its worship, even though no such warrant would be necessary in the first place. The example of Col.3:16 just does not fit into the view that our singing in worship must be restricted to inspired words.[16] Advocate 2's only defense is that since it is possible that the verse "may only refer to informal practice" (rather than formal worship), therefore it is not necessary that singing uninspired hymns in worship is allowed.[17]

But of course this has nothing to do with my argument anyway. I am not claiming that Col.3:16 necessarily refers to singing in worship, but simply that in actuality this happens to be what Paul is talking about. In my last essay I gave reasons why this is the natural reading of the text and why Advocate 2's view is very odd. He has not chosen to reply to those reasons. If I am correct in fact about this verse - and Advocate 2 has not attempted to show otherwise - then he has been refuted on his own grounds. Clinging to "maybe's" will be useless here.

Those Reformed believers who use uninspired hymns in worship do not, as portrayed by Advocate 2, do so because they reject or misapply the regulative principle of worship. Nor do they do so because they are dispensationalists (or, as he most recently altered the charge, no better than Reformed Baptists) regarding the unity of the covenant of grace. Perpetuating these misconceptions will not buttress the fallacious and unbiblical argument that singing in worship must be restricted to inspired words. I am confident that Advocate 2 would join me in encouraging the thoughtful reader to look beyond such characterizations and to decide the theological issue simply on the merits of the case. Let us think clearly and consistently. And as always, sola Scriptura.

[1] Westminster Confession of Faith XXI.1: the acceptable way of worshipping God is limited by His own will, so that He may not be worshipped in any way which is not prescribed in the Holy Scripture.

[2] But at least one of us must be guilty of such an error since we have reached contradictory conclusions - and truth is not relative.

[3] After all, exclusive psalm-singers do not accuse John Murray of not truly believing the regulative principle because he felt it appropriate to sing Scripture songs other than the Psalms. The difference between them was one of application.

[4] The reader will notice, then, that my argument does not at all - as alleged by Advocate 2 - rest upon the Lutheran and Anglican view that only what is forbidden in Scripture is to be excluded from worship. It rests upon the necessary distinction between circumstance and elements of worship, which has always been part of the Reformed conception of the regulative principle.

[5] Fallacy of false antithesis. We do not have to choose between praise or instruction as the single "essence" of singing in worship. Both functions enjoy Biblical warrant. To say instruction is not really essential, but only "incidental," does violence to Paul's words in Colossians 3:16!

[6] This is not an "argument from analogy," as Advocate 2 tries to make it. It is a reductio ad absurdum based on a conspicuous inconsistency in the application of the regulative principle found among exclusive psalm-singers.

[7] These are notorious logical fallacies: (1) name-calling and (2) arguing from the possibility of abuse. Moreover, Advocate 2 shows that he has not understood the argument yet when he speaks of "the sophistry of pretending that singing God's praise is not an element of worship." That is not my claim at all! It is singing (not "singing God's praise") which is not an element of worship as such.

[8] Well, the Psalms were "humanly composed." Advocate 2 really means songs which were humanly composed, but not under the inspiration of the Holy Spirit.

[9] It is noteworthy that Advocate 2 himself asserts in another context that to argue from a "maybe" is to commit a fallacy.

[10] The cautious reader will notice Advocate 2's attempt to impute guilt by association, placing the singing of uninspired hymns in the same category with "innovation such as dance" - which is not my position whatsoever.

[11] The reader will again notice the attempt to impute guilt by association when Advocate 2 tries to lump me with Lutherans and Anglican - whose views of worship I oppose.

[12] Actually, Advocate 2 refers, not to singing, but rather to "singing God's praise," once again showing that he has not understood the precise object of our discussion (and therefore not understood my argument). See footnote 7 in my previous response.

[13] Of course, trivially, there "is a way" that singing God's praise glorifies Him differently than prayer and preaching does: viz., with music. Advocate 2 must mean something more than this!

[14] Notice also that Advocate 2 cannot decide whether the difference is "radical" (as he says at one point) or "relative," a matter of priorities (as he says here).

[15] That is, even given his own category scheme, Advocate 2 need only restrict "direct praise" singing to inspired words (like the psalms), but the "incidental praise" elements of worship would readily permit singing uninspired words (such as hymns)!

[16] In his reply to my comments on Col.3:16 Advocate 2 misrepresents me as saying the verse "subordinates singing God's praise" to doctrinal instruction. This is off the mark. The language of "subordinating" one function to another is that of Advocate 2, not mine.

[17] The reader will need to read Advocate 2's words many times to untangle his convoluted use (and misuse) of modal expression (e.g, possibility, actuality, necessity, allowability) and double negatives.