Answer
Jude 1:9 refers to an event that is found nowhere else in Scripture. Michael the archangel had to struggle or dispute with Satan about the body of Moses. What that entailed and why it happened is not described. Was it an argument over possession of the body, the burial of the body, or something else?
A different angelic struggle is found in the book of Daniel. An angelic being rouses Daniel from a deep sleep (Daniel 10:7–11). The heavenly messenger tells Daniel that he was “resisted” by an entity called “the prince of the Persian kingdom.” After 21 days, the archangel Michael came to the first angel’s assistance (Daniel 10:13), allowing the angel to bring Daniel the message God wanted him to hear. So, we learn from Daniel that angels and demons fight spiritual battles and that the demons resist God’s holy angels and try to prevent them from doing God’s bidding.
Jude tells us that Michael the archangel contested Satan himself. Michael had been sent by God to deal in some way with the body of Moses. For the circumstances regarding Moses’ death, see Deuteronomy 34:1–8.
Various theories have been put forth as to what this struggle over Moses’ body was about. One is that Satan, ever the accuser of God’s people (Revelation 12:10), may have resisted the raising of Moses to eternal life on the grounds of Moses’ sin at Meribah (Deuteronomy 32:51) and his murder of the Egyptian (Exodus 2:12).
Some have supposed that Jude’s reference is to the same event recorded in Zechariah 3:1–2: “Then he showed me Joshua the high priest standing before the angel of the Lord, and Satan standing at his right side to accuse him. The Lord said to Satan, ‘The Lord rebuke you, Satan!’” But the only similarity between the two passages is the expression, “The Lord rebuke you.” Also, the name Michael does not occur in the passage in Zechariah, and there is no mention of the body of Moses.
Some surmise that Jude is quoting a non-canonical book that contained this account and that Jude means to confirm that the account is true. Origen (c. 185–254), an early Christian scholar and theologian, mentions a book called the Assumption of Moses as extant in his time, containing this very account of the contest between Michael and the devil. That book, now lost, is what Origen supposed was the source of the account in Jude.
The only material question, then, is whether the story of Michael’s dispute with the devil is “true.” Jude seems to refer to the confrontation as factual. He speaks of it the same way he would have spoken of the death of Moses or his smiting the rock. And, of course, no one can prove that it is not true. There are many allusions to angels in the Bible. The archangel Michael is real, and the devil is mentioned frequently in Scripture. There are numerous biblical affirmations of the existence of both bad and good angels, and some of their work on earth is detailed. Concerning the dispute over Moses’ body, the nature and purpose of the incident is wholly unknown, making conjecture useless.
Jude 1:9 provides an example of how Christians are to deal with Satan and his demons. Michael’s refusing to pronounce a curse upon Satan should be a lesson to Christians in how to relate to demonic forces. Believers are to seek the Lord’s intervening power against the forces of darkness. If a being as powerful as Michael deferred to the Lord in dealing with Satan, who are we to attempt to reproach, insult, or command demons in our own strength?
