I've discussed many problems with it in a lot of posts over the years, but I want to provide a list in one place. I'll include a link to a post addressing each of most of these items. This isn't meant to be exhaustive:
- There are no Biblical examples of people being justified at the time of baptism.
- There's a double-digit number of examples of people being justified apart from baptism, including passages that are explicitly or implicitly referred to as normative.
- There's often evidence of a significant change in a person's life prior to baptism, not just in the Biblical examples discussed above, but also in many extrabiblical cases found from the earliest history of the church down to our day.
- The lack of reference to baptism in the vast majority of Biblical (and some extrabiblical) passages discussing justification makes more sense if baptism isn't a means of justification.
- The setting justification is described as normally occurring within is prebaptismal.
- Baptismal regeneration violates the Biblical principle of the immediate availability of the means by which we're justified.
- Baptismal regeneration violates the Biblical principle of the chronological immediacy of justification.
- Baptism should be considered a work, which makes baptismal regeneration inconsistent with the Biblical rejection of justification through works.
- Josephus referred to the non-justificatory nature of the baptism of John the Baptist, and the parallels between Josephus and 1 Peter make the most sense if Peter also thought baptism is non-justificatory.
- The non-justificatory nature of multiple early forms of baptism (a point often acknowledged by advocates of baptismal regeneration) makes more sense if the form Christians practice today is non-justificatory as well.
- Justification apart from baptism makes more sense of what Jesus and multiple other early sources said about continuity in how people are justified throughout history.
- Jesus often healed people both physically and spiritually at or around the same time, which involved justification apart from baptism, a phenomenon I've referred to as double healing. That double healing phenomenon continued into the book of Acts, which makes more sense if justification apart from baptism continued into the timeframe covered by Acts rather than ending earlier (as advocates of baptismal regeneration claim).
- Most of the earliest extrabiblical sources seem to have believed in justification apart from baptism, and some later pre-Reformation sources did as well, despite the later popularity of various views of baptism that involved a higher level of efficacy.
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