• Joshua Moffit

The Sovereign Freedom of God

Our Free Will Cannot Contain Him

As Solomon dedicated the newly built temple he cried out, “Will God indeed dwell on the earth? Behold, heaven and the highest heaven cannot contain you; how much less this house that I have built!”[1] Solomon was amazed that the transcendent God of the universe could at the same time be the immanent God who made his name to dwell in the midst of his people.[2] Yet, Solomon did not see these two truths in conflict. Rather, Solomon believed that it was God’s transcendence, his freedom from creation, that gave God the sovereign freedom to be a God of immanence, his freedom for creation. Solomon’s belief in both gave him the confidence that his covenant keeping God not only had the sovereign ability, but also the willingness to “hear” and “forgive.”[3]

The relationship between God’s freedom and human freedom is analogical rather than univocal confirming God’s sovereign freedom.

In contrast to the god of Open Theism and its related cousins, Panentheism and Process Theology, the God of the Bible has complete sovereign freedom as Creator, and humans made in God’s image have complete creaturely freedom, which is analogical to God’s freedom.[4] Michael Horton argues:

It is not in some reality above and beyond God, shared by the creature, that humans have freedom – an area of autonomous freedom. Rather, it is in God’s sovereign reign that creatures have creaturely freedom in the first place…freedom…is at least for Christians defined by God as its source and therefore as the one who normatively defines it. Freedom is not autonomy.[5]

Human freedom is derived from and analogical to God’s freedom. Indeed, all human knowledge of God is analogical since God is incomprehensible and yet knowable, transcendent and yet immanent. God’s freedom is the archetype. Human freedom is the ectype.


God’s sovereign freedom has come under attack throughout the history of the church by prominent figures such as Pelagius and Arminius. Recently, it has come under attack by advocates of the view of Open Theism, which takes the views of human libertarian freedom to their logical conclusion by denying God’s foreknowledge of decisions made by free moral creatures believing this future cannot be known if moral creatures are to be free.[6] John Sanders argues that God cannot foreknow with certainty anything that involves free human decisions because this would render future human decisions certain, which according to a view of libertarian free will is impossible.[7] Sanders’ assessment of free will theism is correct; if libertarian freedom is to be upheld then Open Theism is its logically consistent conclusion. However, the debate between Open Theism and Classical Theism is not principally a debate over God’s foreknowledge even if that is the sphere in which most of the debate takes place. Open theists may claim that the debate is “completely a debate over the nature of the future.”[8] In reality, it is at its core a debate over the very nature of God and a blurring of Creator/creature distinctions foundational to Classical Theism.[9]


Open theism errs in placing an abstract view of freedom as sovereign over both God and man, rather than accepting the sovereign freedom of God as the basis for human freedom. Human free will is viewed as univocal with the free will of God.[10] As a result, open theists have managed to contain Solomon’s uncontainable God. In their view, God cannot overstep his bounds into the realm of human free will. Indeed, he cannot even know the decisions made by the autonomous will of free human agents before these decisions are made. Therefore, the future is “open” to any number of possibilities unknowable and uncertain to God before they actually happen. The Open Theists’ view of God is a “humanized” view of God that overly emphasizes God’s immanence by sacrificing his transcendence.


Conversely, by holding human freedom as analogical to and not univocal with God’s freedom a person may affirm both the sovereign freedom of God and human freedom (and responsibility) as the Bible does without seeing the two in conflict. Creator and creature distinctions are maintained while still affirming real significance to human decisions. The Westminster Confession of Faith correctly asserts that God did “by the most wise and holy counsel of His own will, freely, and unchangeably ordain whatsoever comes to pass: yet so, as thereby neither is God the author of sin, nor is violence offered to the will of the creatures; nor is the liberty or contingency of second causes taken away, but rather established.”[11] God’s sovereign freedom does not violate the free will of human beings; rather it is the foundation of the very existence of the secondary causes which Open Theists claim to be autonomous from the sovereignty of God.


A God Like Us: Open Theism and Libertarian Free Will

Open Theism is strongly opposed to the WCF 3.1. Frequently, they wrongly characterize their Reformed opponents by emphasizing God’s sovereign ordaining in WCF 3.1, while leaving out the affirmation of secondary causes.[12] Open Theists deny that genuine human freedom can exist if God is sovereign over it. For human freedom to be real, humans must be free “even to maneuver themselves out of the range of the divine reach.”[13] Therefore, in the open view, human freedom must be autonomous and exist in a realm outside of God’s sovereignty to be “genuine.” Pinnock expresses his inability to reconcile libertarian freedom and the classical view of divine sovereignty:

I do not see how one can have genuine freedom (human and divine) and exhaustive definite foreknowledge. Future free acts, by definition, cannot be known in every detail and for certain even by God. It is enough to say that God knows everything any being could possibly know, which leaves room for human persons to act and also room for God to act, since the future is open to both. [14]


Pinnock’s inability to reconcile freedom and foreknowledge lies in his presupposition that freedom must be univocal for God and man. God and man are on the same playing field in the realm of freedom. Like two cars on a highway, God’s freedom cannot cross the yellow line without resulting in a severe collision with human freedom. There must be “give and take” in the relations of God and man since libertarian freedom is “necessary for personal relationships of love to develop.”[15] This view of freedom may be true of human to human relations. One man’s freedom cannot assert itself over the decisions of another man without a loss of freedom. Therefore, there must be “give and take” for freedom to be maintained between individuals. But it begs the question, “Is God like us?” Is the God of the Bible limited in his freedom to being just another player vying for his slice of the freedom pie?

This presupposition of the Open Theists is debatable. Why can’t God have sovereign freedom and humans have creaturely freedom simultaneously? The playing field is not the same. God is not just the most powerful player on a field of many players. Our unique God is in a completely separate category of his own.[16] God is the Creator; humans are the creatures.[17] God is free to do his will, and humans are free to do their will but not in a univocal way. Richard Muller defines freedom:

God is free in being and in action, in self and in relation to God’s creatures; God’s sovereignty is a sovereign freedom; and God’s power is a free exercise, devoid of all constraint…Human freedom, unlike the freedom of God, is a relative freedom [I would say analogical], bounded not only by our nature as given in the act of creation but also by the acts of other creatures, by the natural order around us, and by our sinfulness.[18]

God ordains whatsoever shall come to pass, but that does no violence to the will of the creatures. The two are not mutually exclusive nor are they univocal.

In Genesis 50:19-20, Joseph recognizes the sovereign good purposes of God even in the evil action of his brothers.[19] Joseph’s brothers sold him into slavery under no compulsion. They were free to choose that for which they “meant evil.” However, God meant the very same act “for good.” The text does not state that God turned the brothers’ evil act into good. Rather, God simultaneously acts for good while the brothers act for evil in the same action. God ordained it for the saving of many even while Joseph’s brothers were free to do evil.[20] God’s sovereign freedom in providence is not limited by the free actions of creatures.

Similarly, in Philippians 2:12-13, Paul’s command to “work out your own salvation with fear and trembling” is followed by the declaration that it is “God who works in you both to will and to work for his good pleasure.” Paul’s belief in the free sovereignty of God does not lead to a passive fatalism as the Open Theists would have us believe.[21] Rather, Paul views the free action of human beings as real and important even as God is simultaneously willing and working for his good pleasure. God is not “omnicausal” but works through secondary causes that carry real significance.


Another passage affirming the simultaneous free sovereignty of God and the free will of creatures is Job 1:21-22. Job proclaims that it is God who gives and takes away. The text clearly portrays Satan as bringing the calamity upon Job, but Job is not concerned with secondary causes. By making the declaration, he is concerned only with the ultimate cause found in God’s ordaining whatsoever shall come to pass. The free (evil) action of Satan and God’s (good) sovereignty were active in the same action for far different purposes. And, in case someone might object that Job falsely gives credit to God for an action that belongs to Satan alone, the text declares, “In all this Job did not sin or charge God with wrong.” God is free to be sovereign even as his free moral creatures are free to act as they choose. The latter does not negate the former.[22] D.A. Carson explains, “God’s positive, providential control is compatible with human freedom…human beings are responsible for what they do, because they do what they want to do.”[23] Simultaneously, God “does all that he pleases” and “works all things according to the counsel of his will.”[24]


In seeking to uphold libertarian freedom, Open Theists have made God like us. They present a false dichotomy that forces us to choose between God’s sovereignty and human freedom. God is free in the same way that humans are free. In seeking to make God more personal and relational, Open Theists believe that God relinquished some of his sovereign freedom.[25] God can be relational only if libertarian freedom is upheld. God looks less like the “King of ages, immortal, invisible, the only God” and more like a nice next door neighbor who can sway personal decisions but is certainly not sovereign over them.[26] A.B. Caneday summarizes the error of Open Theism and provides the proper way to view God:

The error is to project back upon God our creaturely restrictions of qualities received from him who made us in his image and likeness…God made us in his image; he forbids us to cast him in our image…God is not like us. We are like God.[27]

The Condescending God: An Analogical View of Free Will

Human freedom is derived from and analogical to God’s freedom. We are like God. However, this does not make God like us. Cornelius Van Til said that “we are like God but we are always creatures! So we are also more unlike God.”[28] God is transcendent and incomprehensible. Isaiah says, “To whom then will you compare me, that I should be like him? says the Holy One… for I am God, and there is no other; I am God, and there is none like me.”[29] Only God has life in himself, and he is not “served by human hands, as though he needed anything, since he himself gives to all mankind life and breath and everything…for ‘In him we live and move and have our being.’”[30] Human freedom cannot be properly understood apart from God’s freedom, but God’s freedom cannot be fully comprehended for his “greatness is unsearchable.”[31] Fortunately, this transcendent Lord is also not the unknowable god of deism.

God has made himself known.

God makes himself known through covenant. Covenant is the place where God reveals himself to human beings, or as Horton puts it, “The covenant is the place where a stranger meets us.”[32] Horton uses this phrase to emphasize the fact that God is not like us. God is a stranger and yet he condescends from glory unimaginable to be in relation with his creatures through covenant. This phrase emphasizes that God is both transcendent and immanent.

Caneday argued that Open Theists fundamentally err by seeking to “know God as he truly is in himself,” that is, in his very essence and being.[33] However, as finite creatures, it is impossible for humans to know the infinite God in his essence. Accordingly, the god of Open Theism tends to look very human.[34] This is the inevitable conclusion if one seeks to peak into the being of God. Either God must be lowered to the level of a creature or humans must be raised to the level of God. God is unknowable in his being because creatures do not share the being of God. Being is not univocal. God is qualitatively (not just quantitatively) distinct from his creatures.[35] Through covenant God reveals himself as a “who” and not a “what.” Horton states, “That is not to deny God’s essence, but to recognize that this is hidden from us. Speculation yields a ‘what,’ but the biblical drama renders a ‘who.’”[36] For the “secret things belong to the Lord our God, but the things that are revealed belong to us and to our children forever.”[37] The “what” is unknowable, but the “who” is our Creator and Redeemer revealed to us in the Bible by what he does (through his word and works) not by what he is.


It is necessary to understand that God, in order to reveal himself to finite creatures, must accommodate to our understanding. The infinite transcendent God chooses to reveal himself to the finite capacities of the human mind. This requires analogies. Pinnock suggests that to take the language of the Bible as “accommodated language” is not to take it seriously.[38] This is ironic considering that all of the Bible is accommodated language! God condescends to human finite capacities to communicate truths about himself. We can trust that the analogies are true because God himself creates the analogies! However, this does not mean that we must take it to mean that we have access to the very being of God.

Caneday effectively argues that Open Theism’s basic beliefs include:

1) that God’s self-revelation with human categories requires the categories to mean the same thing when used of God as when used of humans; 2) that if we do not know God as he truly is, then we do not truly know God.[39]

Pinnock claims that the open view “model take[s] Scripture very seriously, especially the dynamic, personal metaphors, while our critics seem to consider it beneath them. Embarrassed by biblical anthropomorphisms, they are inclined to demythologize and/or deliteralize them.”[40] Open Theists tend to believe that if something is analogical (i.e. doesn’t communicate the essence/being of God) then it does not really communicate truth about God rendering God unknowable. However, just because something is analogical does not mean that it does not convey truth. God as “Father” does not need to be taken “literally” in order to communicate real truth about God and our relationship to him. Analogical knowledge of God is still true knowledge of God.


God himself cautions against seeking to know him in his essence rather than through covenant. In Exodus 33:18, Moses asked to see God’s glory. God’s gracious response was to hide Moses in a cleft of a rock and let him see his backside. Anything more would surely have been the death of Moses.[41] As Caneday argued, even as God reveals himself he:

hides himself from us, lest he consume us…All of God’s revelation is analogical…Right thinking about God necessarily acknowledges that the analogical relationship between Creator and creature entails both similarities and dissimilarities…When the incomprehensible God reveals himself to us, he also veils his glory from us, so we cannot know God as he is fully and truly in himself…Yet, to the degree God has pulled back the veil to make himself truly known, we can truly know God, and this is enough.[42]

We need not fear that upholding God’s uniqueness, aseity, and incomprehensibility will render him unknowable. God condescended to his creatures to make himself known through analogy. Horton argues that “Although our knowledge doesn’t penetrate the archetypal self-knowledge of the Trinity, it is ectypal of it. Our knowledge does have ultimate reality as its foundation even if the former has an analogical relation to the latter.”[43]


Lord of the Covenant: The Sovereign Freedom of God to be ‘God With Us’

God has an absolute claim on all of creation for he “created all things” and by his will they exist.[44] “To the Lord your God belong heaven and the heaven of heavens, the earth with all that is in it.”[45] However, the biblical God of Christianity is not Islam’s Allah who simply demands submission. In declaring that God is the absolute sovereign ruler of the universe, the Bible also declares a “yet.” “Yet the Lord set his heart in love” upon his covenant people.[46] God is Lord of the covenant to be sure. The covenant is not an agreement between equal parties as if God needed humans.

Yet, out of an overflow of love from the Trinity the Lord chose to Create and Redeem.

God does not relate to humans in a “give-and-take relationship of love” leaving things to “chance” or “accidents” as John Sanders suggests.[47] For “who has given a gift to him that he might be repaid? For from him and through him and to him are all things.”[48] It is because God is independent from the world and does not need the world that he is truly free to “set his heart in love” upon the world. God is not bound by human free will or an abstract “realm of freedom.”


God is not dependent upon the world for his happiness, and does not require the world to attain the fullness of his being. God is absolute: free, sovereign, holy, and perfect in every way. Barth says that “God is free in his relationship to all that is not God,” which means that he “cannot be classified or included in the same category with anything that he is not.”[49] It is this very freedom of God from creation that is the grounds of God’s being free for creation. We are back to Solomon’s uncontainable God who nevertheless makes his name to dwell in the midst of his people! This biblical God bound “only by his nature” has at the same time “bound himself to us by a free decision to enter into covenant with us.”[50] It is precisely because God has sovereign freedom that his people can trust in his promises that he will “hear” and “save.”


God brought (and bought) salvation when he became incarnate in Jesus Christ. God is not “like us,” but he chose to be “God with us” in order to “save his people from their sins.”[51] Jesus Christ fulfilled the covenant on behalf of his people in order to save them from their sin and depravity and set them free. This human freedom is not autonomy from God but rather freedom to love God. The goal of human freedom is not to reach autonomy but to “choose to be righteous” without even the possibility of sinning. True freedom is “freedom not to sin.”[52]

As a result, human beings will be most free in glory! True freedom is dependence on God, not autonomy from him. Christians must affirm the sovereign freedom of God for it is the very foundation of the hope we have for salvation. The view of Open Theism gives no assurance that God will ultimately fulfill his purposes or save us from our own sinfulness. God’s transcendence allows him to give completely of himself without needing anything in return. Therefore, God is able to show mercy and grace to sinful people. God’s sovereign freedom does not restrict his relationship with humans, but is the basis for his drawing us near to him through covenant. God is able to freely enter into relationship with his creatures because he himself is free. As Horton states, “God is more transcendent and more immanent than we can imagine…God’s freedom for creation--even for those who are not only finite but sinful--is the presupposition of our hope in Christ.”[53] Christ “is able to save to the uttermost those who draw near to God through him, since he always lives to make intercession for them.”[54] “So if the Son sets you free, you will be free indeed.”[55] Against Open Theists’ claims, we shall uphold God’s sovereign freedom confessing that God:

Rules and governs…according to His holy will, so that nothing happens in this world without His appointment...For His power and goodness are so great and incomprehensible that He orders and executes His work in the most excellent and just manner…as to what He does surpassing human understanding, we will not curiously inquire into farther than our capacity will admit of; but with the greatest humility and reverence adore the righteous judgments of God, which are hid from us, contenting ourselves that we are pupils of Christ, to learn only those things which He has revealed to us in His Word.[56]


"But will God indeed dwell on the earth? Behold, heaven and the highest heaven cannot contain you; how much less this house that I have built! Yet have regard to the prayer of your servant and to his plea, O Lord my God, listening to the cry and to the prayer that your servant prays before you this day, that your eyes may be open night and day toward this house, the place of which you have said, ‘My name shall be there,’ that you may listen to the prayer that your servant offers toward this place. And listen to the plea of your servant and of your people Israel, when they pray toward this place. And listen in heaven your dwelling place, and when you hear, forgive.” - 1 Kings 8:27–30



[1] The Holy Bible : English Standard Version (Wheaton : Standard Bible Society, 2001), 1 Kings 8:27. Cf. 2 Chron. 6:18. All Biblical citations are ESV unless otherwise noted. [2] 1 Kings 8:29; Deut. 12:11. [3] 1 Kings 8:30. [4] The human freedom defended in this blog is not autonomous freedom nor the power of contrary choice. The author understands that the Bible depicts post-fall unredeemed humans as totally depraved and enslaved to sin. The focus of this paper is to establish a proper relationship between God’s freedom and human freedom, which is analogical. Human freedom does not necessitate the power of contrary choice. God himself does not have the power of contrary choice for he cannot act against his nature. So to define freedom in this way would be to deny God’s freedom. Freedom in general is best described as the ability to act according to one’s nature with the ideal for humans of being not able to sin. [5] Michael Horton, “Hellenistic or Hebrew? Open Theism and Reformed Theological Method,” Beyond the Bounds, 233. [6] Mark Talbot argues that Open Theism is the logical conclusion of any view of free will theism saying, “Open theism is free will theism taken to its logical extreme in that it argues that, insofar as God has given us libertarian free will, even he cannot truly know what choices we will make; and so the portion of the future that will be determined by still-unmade free human choices is ‘open’ and unknown to him as well as to us.” Mark Talbot, “True Freedom: The Liberty That Scripture Portrays as Worth Having,” in Beyond the Bounds: Open Theism and the Undermining of Biblical Christianity (Wheaton, IL: Crossway Books, 2003), 94. [7] John Sanders, “Be Wary of Ware: A Reply to Bruce Ware,” JETS 45 (June 2002): 224-226. [8] Gregory Boyd, God of the Possible (Grand Rapids, MI: Baker Books, 2000), 17. For good arguments against Open Theism in this aspect of the Open Theist debate (i.e. God’s foreknowledge) see John Hammett, “Divine Foreknowledge and Open Theism,” Faith and Mission 21 (Fall 2003): 18-29. Cf. Bruce Ware, “Defining Evangelicalism’s Boundaries Theologically: Is Open Theism Evangelical?” JETS 45 (June 2002): 193-212. [9] Process theology, a view which has crept into evangelical circles as demonstrated by the popular music artist Dustin Kensrue, imagines a god who like his creation is always changing and evolving. https://www.jeremyhoward.net/2019/11/its-not-enough-dustin-kensrues-turning.html [10] Univocity of freedom is the downfall of all views of libertarian free will – Pelagian, Arminian, etc. However, this article will focus only on that view as it is espoused by Open Theists. [11] The Westminster Confession of Faith, (Oak Harbor, WA : Logos Research Systems, Inc., 1996), Chapter III, 1. [12] Pinnock even characterizes the Calvinistic view as “omnicausal” even though the WCF clearly affirms secondary causes through human agency. Pinnock conveniently leaves out this aspect when quoting the WCF 3.1. Clark Pinnock, Most Moved Mover: A Theology of God’s Openness (Grand Rapids, MI: Baker Book House, 2001), 9. [13] Clark Pinnock, “There is Room for Us: A Reply to Bruce Ware,” JETS 45 (June 2002): 215. [14] Pinnock, “There is Room for Us,” 216. [15] Pinnock, Most Moved Mover, 5. [16] Commenting on our understanding of the compatibility of divine sovereignty and human responsibility Mark Talbot states, “It is because attempts on our part to understand it involve our trying to understand the unique relationship between the Creator and his creatures in terms of our understanding of some creature-to-creature relationship. But this attempt, it should be clear, involves us in a kind of ‘category mistake’ that dooms our attempt from the start.” Talbot, “True Freedom,” Beyond the Bounds, 99. [17] A.B. Caneday has a helpful comment, “Because God is the sovereign Creator, and not a creature, he does not relate to his creatures as one creature relates to another. As the one who made us, he has his own divine ways to move us to do his bidding without violating our wills. God does not coerce his creatures…” Caneday, “Veiled Glory,” Beyond the Bounds, 179. [18] Richard Muller, “Freedom,” in The Westminster Handbook to Reformed Theology (Louisville, KY: Westminster John Knox Press, 2001), 87-88. [19]The compatibility of God’s sovereign freedom and creaturely free action are seen throughout the Bible. A quick survey of key texts is sufficient for the purposes of this paper to demonstrate what the Bible proclaims in its entirety. [20] Cf. Gen. 45:5, 7. [21] See Pinnock, “There is Room for Us,” 217-218. [22] John Murray explains, “Foreordination, though all-inclusive, does not operate so as to deprive man of his agency, nor of the voluntary decision by reason of which he is responsible for his action.” John Murray, Collected Writings of John Murray, v. 2 (Carlisle, PA: Banner of Truth Trust, 1977), 64. [23] D.A. Carson, “How Can We Reconcile the Love and the Transcendent Sovereignty of God?” God Under Fire (Grand Rapids, MI: Zondervan, 2002), 292. [24] Psalm 115:3, Ephesians 1:11. [25] As if it was possible for God to cease being God. If sovereignty is part of God’s nature he cannot relinquish it. [26] 1 Timothy 1:17. [27] A.B. Caneday, “Veiled Glory: God’s Self-Revelation in Human Likeness,” Beyond the Bounds, 153, 159, 198. [28] Cornelius Van Til, The Defense of the Faith (Phillipsburg, NJ: Presbyterian & Reformed, 1955), 13. [29] Isaiah 40:25, 46:9. Cf. Isaiah 40:18, 46:5. [30] John 5:26, Acts 17:24-28. [31] Psalm 145:3. [32] Michael Horton, Lord and Servant: A Covenant Christology (Louisville, KY: Westminster John Knox Press, 2005), 11. [33] Caneday, “Veiled Glory,” Beyond the Bounds, 156. [34] Pinnock even suggests that it is “possible that God has a body in some way we cannot imagine.” Pinnock, Most Moved Mover, 34. This bold claim is made in direct violation of biblical teaching which declares that “God is spirit.” John 4:24. [35] See Horton, “Hellenistic or Hebrew?” Beyond the Bounds, 208. Cf. Horton, Lord and Servant, 33. Horton states, “Since there is no predicate of being that God and creatures univocally share, God’s freedom is qualitatively and not simply quantitatively different from our own.” [36] Horton, Lord and Servant, 10. [37] Deuteronomy 29:29. [38] Pinnock, Most Moved Mover, 20. [39] Caneday, “Veiled Glory,” Beyond the Bounds, 189. [40] Pinnock, Most Moved Mover, 61. Yet, what does “deliteralize” even mean? If it means to take biblical language as analogical rather than as conveying the very being of God then the “critics” will gladly accept this. [41] Exodus 33:18-23. [42] Caneday, “Veiled Glory,” Beyond the Bounds, 156, 197-198. [43] Michael Horton, Covenant and Eschatology: The Divine Drama (Louisville, KY: Westminster John Knox Press, 2002), 186. Cf. 181-185. [44] Revelation 4:11. [45] Deuteronomy 10:14. [46] Deuteronomy 10:15. [47] John Sanders, The God Who Risks: A Theology of Providence (Downers Grove, IL: Intervarsity Press, 1998), 276-277. [48] Romans 11:35-36. [49] Karl Barth, Church Dogmatics, vol. 2/part 1 (Edinburgh: T&T Clark, 1957), 310. [50] Horton, Lord and Servant, 33. [51] Matthew 1:21-23. [52] Talbot, “True Freedom,” Beyond the Bounds, 109. [53]Michael Horton, “Lecture to Doctrine of God Class” (lecture, Westminster Seminary California, Escondido, CA, September 9-10, 2009). [54] Hebrews 7:25. [55] John 8:36. [56] “The Belgic Confession,” Historic Creeds and Confessions. electronic ed. (Oak Harbor : Logos Research Systems, Inc., 1997), Article 12.

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