Footnote 5: As Adam Clarke's Commentary quotes Dr. Macknight: "In Daniel 10:13, 21; 12:1, Michael is spoken of as one of the chief angels who took care of the Israelites as a nation; he may therefore have been the angel of the Lord before whom Joshua the high priest is said, Zechariah 3:1, to have stood, Satan being at his right hand to resist him; namely, in his design of restoring the Jewish Church and state, called by Jude the body of Moses, just as the Christian Church is called by Paul the body of Christ. Zechariah adds, And the Lord, that is, the angel of the Lord, as is plain from v. 1, said unto Satan, The Lord rebuke thee, O Satan! even the Lord that hath chosen Jerusalem, rebuke thee!" A strong allusion to Jude's language and perhaps referring to the same incident.

To summarize Clarke's other observations, he notes that the Apostle in Romans 7:24 refers to "the body of sin", meaning the principle of sin itself, not our physical bodies. Thus, for Jude to speak of the "body of Moses", he is speaking in the same sense as Jesus does to "the seat of Moses" (Matthew 23:2) - the nation and authority established by Moses. Among the Jewish rabbis, Samael is the name for Satan - as says the Book of Enoch, which Jude also quotes - who opposes Michael in the battle over Israel. Samael is the accuser and Michael is Israel's advocate before the Judge of Heaven.

Richard Baukman in his important study, Jude and the Relatives of Jesus in the Early Church, (T&T Clark, Edinburgh, 1990), marshals the writings of the early Fathers to show that it was indeed a dispute over the body of Moses (Satan charging Moses with the murder of the Egyptian) but that it was not the central message which Jude was wanting to convey. Rather, it was how the archangel handled the confrontation which was central:

It is important to take account of the fact that in our reconstruction of the story the devil appears in his ancient role as a legal accuser trying to prove Moses' guilt. This means that Michael's behaviour is exemplary not in his treatment of the devil himself (in treating the devil with respect) but in his response to the accusation brought by the devil. Even though he recognized it as slanderous, he could not dismiss it because he was not the judge. Therefore the moral of the story is that no one except God is in this sense a judge, a moral authority. Even if it were true, as the false teachers alleged, that when the law accused them of sin it was only the malice of the angels that prompted these accusations, they would still not be justified in rejecting them on their own authority. Even if they were as righteous as Moses and had the authority of an archangel, they would not be above accusations of sin under the law. They remain subject to the moral authority of the Lord. We can finally see that verse 9 is linked not only to the third of the charges against false teachers in verse 8 (they "slander the glorious ones") but also to the second (they "reject the authority of the Lord").

p. 274-275

Baukman here sees Jude challenging the Gnostic teachers' supposition that they can reject the moral authority of Old Testament law because, according to their cosmology, it was mediated and enforced by fallen angels. Jude reminds them that the law still finds its point of origin in God Himself and that Satan, while a fallen creature, still must do God's bidding.

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