In the epistle of Jude, the inspired writer brings up a dispute that took place between the archangel Michael and Satan over the body of Moses:
“Yet in the same way these dreamers also defile the flesh, reject authority, and slander the glorious ones. But when the archangel Michael contended with the devil and disputed about the body of Moses, he did not dare to bring a condemnation of slander against him, but said, “The Lord rebuke you!’” Jude 1:8-9 New Revised Standard Version (NRSV)
This is a difficult passage to interpret since Jude includes information not found in the canonical books of the Holy Bible, particularly the issue of Michael’s rebuking Satan over Moses’ body, a story that is not in the inspired Scriptures.
The following commentaries help explain the point Jude is seeking to make and why he chose to bring up this dispute between the archangel and the devil:
9 The example Jude gives is not that of an OT story, but of an intertestamental expansion upon such a story. The biblical story of the death and burial of Moses in Deut 34:1–12 is known, if not exactly familiar. The essential information is in the first six verses of the chapter, specifically in vv. 1 and 4–6:
Then Moses went up from the plains of Moab to Mount Nebo, to the top of Pisgah, which is opposite Jericho, and the Lord showed him the whole land: Gilead as far as Dan, … 4 The Lord said to him, “This is the land of which I swore to Abraham, to Isaac, and to Jacob, saying, ‘I will give it to your descendants’; I have let you see it with your eyes, but you shall not cross over there.” 5 Then Moses, the servant of the Lord, died there in the land of Moab, at the Lord’s command. 6 He was buried in a valley in the land of Moab, opposite Beth-peor, but no one knows his burial place to this day.
Clearly that story mentions neither “the archangel Michael” (found in the OT only in Dan 10:13, 21; 12:1) nor the devil (which is a Greek term appearing twenty-two times in the Greek OT, but only in translating postexilic books, i.e., Esther, Job, Zechariah, and once each in 1 Chronicles, Psalms [108:6], 1 Maccabees, and Wisdom of Solomon; when it translates a specific Hebrew term it is usually translating “Satan”). According to the church fathers, starting with Clement of Alexandria (Fragments on the Epistle of Jude), the reason for this is that Jude is citing, not the OT, but the Assumption of Moses. (Clement wrote, “’When Michael, the archangel, disputing with the devil, debated about the body of Moses.’ ” Here he confirms the Assumption of Moses. He is here called Michael, who through an angel near to us debated with the devil.”) Thus there is universal agreement that Jude is citing an apocryphal work.
The problem arises in finding the work and thus the context to which Jude is referring. While no extant writing contains the story to which Jude refers, the so-called Milan manuscript contains the bulk of a first-century work called The Testament of Moses, and it is the lost ending to this book that Bauckham argues forms the basis for Jude’s story. From other references to this work the lost ending can be reconstructed: After the death of Moses Michael came to bury his body. The devil (Samma’el, one of a variety of Jewish names for the devil) came and argued that the body should be given to him, for Moses had been a murderer (i.e., he had murdered the Egyptian, Exod 2:12–14) and thus did not deserve an honorable burial. When Michael appealed to the judgment of God with “The Lord rebuke you!” the devil withdrew, knowing that God would decide in favor of Moses’ honor and against his slander.
Given this background, we can now explore what Jude is trying to communicate. First, starting in the OT Michael is cited as an angelic being (called a “prince” in Daniel) who is the protector of Israel (Rev 12:7; 1 QM 17; cf. b. Hagigah 12b; b. Menahot 110a for rabbinic references to Michael). He is identified as one of the four or seven chief angels (e.g., 1 Enoch 20:5; 40:9), and often as the head of the group. The term “archangel” appears in the NT only here and in 1 Thess 4:16; the term appears otherwise only in pseudepigraphical works (thirty-eight times), such as the Greek text of 1 Enoch 20:7; Jub. 10:7; Life of Adam and Eve 1; 22:1; 37:4; Test. Abr. 1:4, 6; 10:1. It also appears in later Christian writings. “Archangel” indicates a chief angel, and thus is the equivalent of Daniel’s “chief prince” or the rabbinic “angels of the presence.” Thus Michael is presented as a figure known to Jude’s readers who is one of the chief angels of God.
Second, in our story Michael is involved in a dispute with the devil. There is a long tradition of disputes between the devil and angels, starting with the “angel of the Lord” in Zech 3:2 and stretching on through the Dead Sea Scrolls (CD 5:17–18; 1QS 3:18–25), pseudepigrapha (T. Ash. 6:4–6), and early Christian works (Hermas, Man. 6:2:1). This particular dispute involves the body of Moses. Thus Moses is already dead, and at issue is the disposition of his body. While Deut. 34:6 says that God buried him, by the time of the Greek translation of this text it was interpreted as “they buried him,” probably indicating angels acting on God’s command. Thus it would not surprise a reader of the Greek OT to discover the presence of Michael in this scene. What might surprise them a little would be the presence of the devil. The exact issue between Michael and the devil is not stated; we may presume that Jude expected his readers to be familiar with the story. Furthermore, the issue itself does not play a role in Jude, so it does not need to be mentioned explicitly.
Third, the point of the citation is the response of Michael. There are two parts to this response. The first is what he did not do, while the second is what, in contrast, he did do. What he did not do is “dare to bring a slanderous accusation against him.” This is an extremely difficult phrase, which needs to be unpacked. The verb “to dare” appears sixteen times in the NT. It indicates taking a risk, and in particular a risk in terms of honor or shame. Thus in Matt 22:46 (par. Mark 12:34; Luke 20:40) people no longer dared to asked Jesus questions (which challenged his honor), for they saw what had happened in the previous instance. In Mark 15:43 Joseph risks his honor by going in and requesting Jesus’ body from Pilate, as do the Philippians in preaching the gospel in Phil 1:14. In each of these cases people risked shame by stepping beyond the bounds of social propriety, but received honor from the writers of the respective books. In Acts 7:32 Moses does not dare, which indicates that he kept his proper place in relationship to God. Likewise Paul keeps his proper place in Rom 15:18; cf. 2 Cor 10:2, 12; 11:21. Thus Michael is pictured here as keeping his proper place, which contrasts with the angels of v. 6, who failed to remain in their proper place.
The phrase “to bring a judgment of slander” (to translate it literally) occurs in the NT only in here and in 2 Pet 2:11, which we believe is dependent upon this passage. The closest that the LXX comes is in Isa 42:3, but that passage does not include the critical term “slander” (blasphēmia). Thus it is unlikely that Jude is depending upon a text that we know. Two interpretations of our passage in Jude are currently argued. The first, argued by Kelly, is that of the NIV, “he did not dare to bring a slanderous accusation” against the devil. This fits into the context in that it would contrast with the actions of the false teachers who “slander (blasphēmou sin) celestial beings.” The problem with this is that (1) it is difficult to see how one could slander the devil, and especially in a situation in which he was opposing the command of God, and (2) it is not characteristic of Scripture to be considerate of the devil’s reputation (cf. John 8:44; Acts 13:10; 1 John 3:8; Rev 12:9, all of which speak negatively of the devil).
The other interpretation, argued by Bauckham and Neyrey, is that of the NRSV, “to bring a condemnation of slander against him.” This would be parallel to Acts 19:40, where the charge of rioting is mentioned. While this interpretation does not fit the charges against the interlopers in the previous verses as well, which would mean that the verses are linked by a catchword connection, it does fit the flow of the argument. The false teachers slander angels, probably accusing them of foisting the law with its moral requirements upon Moses. By way of contrast, Michael, whose position was indisputable, when disputing with the devil in a narrative in which the devil was slandering the character of Moses, would not accuse this fallen angel, whom all agree is evil, of slander. In doing this Michael REFUSED to overstep his proper boundaries AND TAKE THE PLACE OF GOD IN JUDGING EVIL.
It is this latter position that appears to have the most evidence to commend it. First, it avoids the problem of having to figure out how one could slander the devil. Second, it provides a cogent reason for Jude’s citing the particular incident that he does, namely, an incident in which the devil is slandering Moses. Third, it provides a counterexample to the false teachers in that Michael does not overstep his bounds on a topic on which his accusation would be justified, while they do overstep theirs in an area in which their accusations are not justified.
Jude’s negative statement leads to a description of what Michael did do; he said, “The Lord rebuke you!” This phrase is itself a quotation of Zech 3:2. There in another judgment scene the Satan (the article indicates that in Zechariah Satan is the name of an office and not yet a personal name) stands ready to fulfill his function of accusing Joshua, who is present there in filthy clothing, indicating at least cultic impurity and possibly moral guilt. “The angel of the Lord” is also present, and he utters the phrase “the Lord rebuke you” and then informs Joshua that his guilt has been removed. This phrase, then, is an appeal to the judgment of God. Rather than assert his own authority over Satan, Michael calls upon God to render the appropriate judgment. One cannot be further from the arrogance of the false teachers in their taking the place of God in their slanderous accusations against his angels. Clearly, Jude, like James (4:11–12; 5:9), believes that judging others is totally inappropriate behavior for a follower of Jesus. They are to be like Michael, who refrains from such behavior.
 Davids, P. H. (2006). The letters of 2 Peter and Jude (pp. 61–63). Grand Rapids, MI: William B. Eerdmans Pub. Co. (Michael Green, Tyndale New Testament Commentaries: 2 Peter and Jude – An Introduction and Commentary, General Editor: Leon Morris [Downers Grove, IL: InterVarsity Press, 1987], Volume 18; capital and underline emphasis mine)
9 Verse 9 is a difficult verse, and so at the outset we should state its main point. The opponents insulted glorious angels who were demons, but Michael was so humble that he did not presume to condemn the devil but asked the Lord to rebuke him. The term “archangel” designates Michael’s authority and prominence. In Dan 10:13, 21 he is designated as a “prince” (archōn)—as “the great prince” (ho archōn ho megas, Theodotion) in Dan 12:1. In Revelation he leads the battle against the dragon and the evil angels (Rev 12:7). His prominence continues in other Jewish literature (1QM 9:16; 1 Enoch 9:1; 10:11; 20:5; 24:6).
Even though the Old Testament says the Lord buried Moses (Deut 34:6), speculation arose over his burial since no human being observed the burial place. The puzzling element in Jude is the reference to the argument over the body of Moses between Michael and the devil. The terms used suggest a legal dispute over Moses’ body. By establishing Moses’ guilt, the devil would deprive him of the right of an honorable burial and presumably claim ownership over his body. Michael had every right, it would seem, to criticize the devil since the devil was wicked and his motives were evil, but Michael did not presume to criticize the devil and utter a “reviling judgment” (krisin blasphēmias) against him.
The words Michael pronounced, “The Lord rebuke you!” allude to Zech 3:2. The Old Testament context in Zechariah is significant, for the account in Zechariah represents another incident in which Satan attempted to establish the guilt of one of Yahweh’s servants. Joshua, the high priest, was in the Lord’s presence, but Satan accused him before the Lord (Zech 3:1). We might think that Satan rightly accused Joshua since his “filthy clothes” represented his sin (Zech 3:3–4). But Yahweh pronounced a judgment against Satan in saying “The Lord rebuke you” (Zech 3:2). God’s word brings forgiveness, illustrated by the clean garments with which Joshua was clothed. As Kee has shown, the Lord was not merely reprimanding Satan so that the story merely concludes with a verbal rebuke. Rather, the Lord’s verdict was effective, sealing Satan’s defeat in the courtroom and declaring Joshua’s vindication. Those whom the Lord has chosen are vindicated in his sight (Zech 3:2, 4–5).
Michael’s words in Jude, similarly, do not merely indicate a desire for the Lord to reprimand Satan verbally for bringing an accusation against Moses, as if Satan would receive only a verbal “dressing down.” The Lord’s rebuke would function as an effective response to Satan’s accusation so that Moses would be vindicated, and his vindication would secure his proper burial. The devil probably claimed authority over Moses’ body because of Moses’ sin in killing the Egyptian. Michael did not deny that Moses sinned or defend his behavior. He appealed to the Lord’s rebuke with the confidence that Moses would receive forgiveness by God’s word, with the result that God would remove his defilement (cf. Zech 3:3–5).
Where did Jude derive this story? Unfortunately, the account is not extant in any writing that has been preserved. Traditions of the account have come down to us, and these traditions are carefully sifted by Bauckham in an excursus. The story is reputed to come from a book titled Assumption of Moses. The relationship between Assumption of Moses and Testament of Moses is keenly debated. In his thorough study Bauckham thinks there are two separate traditions in these two different works. The issue need not be resolved by this commentary since we no longer possess the original version of the story. What we do learn from the traditions compiled by Bauckham is that the devil contested Moses’ “right to an honorable burial,” charging him with the murder of the Egyptian.57 Michael asked the Lord to rebuke the devil, and the devil fled so that Michael could complete the burial.
My interpretation differs in one significant respect from Bauckham’s. Bauckham rejects the common view that Michael refused to slander the devil. In his careful and fascinating study of the traditions of the account, he maintains that the story Jude drew on taught that the devil slandered Moses because Moses murdered the Egyptian. The key to grasping what Jude meant, suggests Bauckham, comes from a knowledge of the tradition he appropriated. Hence, the point of the story, according to Bauckham, is not that Michael refused to slander the devil. Michael, according to Bauckham, did not presume to respond to the devil’s accusation against Moses, appealing to the Lord’s judgment, not his own authority as the leader of angels, to counter Satan. Bauckham’s suggestion is intriguing, but I do not believe it is the most natural way to understand the verse.61 In saying that Michael did not presume to bring “a reviling judgment,” it seems most likely that this is a judgment against the devil, in the sense that Michael did not presume, though he seemed to have every right to do so, to speak against the devil. Although Bauckham’s interpretation is ingenious, the words “did not dare to bring a slanderous accusation” are most naturally understood to say that Michael refused to utter a word of judgment against the devil. The verse, then, has a simple contrast. Michael did not dare to pronounce a condemning judgment upon the devil. He left the judgment of Satan IN GOD’S HANDS, ASKING GOD TO FINALLY JUDGE HIM. Such a reading of the verse fits as well with our understanding of 2 Pet 2:10–11.
 Schreiner, T. R. (2003). 1, 2 Peter, Jude (Vol. 37, pp. 458–460). Nashville: Broadman & Holman Publishers. (Thomas R. Schreiner, The New American Commentary: 1, 2 Peter, Jude [Nashville, TN 2003: Broadman & Holman Publishers], Volume 37; underline emphasis mine)