Charles Ellicott Commentary 2 Peter 2:11

"whereas angels, though greater in might and power, bring not a railing judgment against them before the Lord." — 2 Peter 2:11 (ASV)

Whereas angels.—Literally, Where angels—i.e., in circumstances in which angels. This verse, if it refers to the same incident as Jude 1:9, seems at first sight to suggest somewhat in favor of the priority of Jude; for then, only when compared with Jude 1:9, does it become intelligible. The inference is that this is an abbreviation of Jude, rather than Jude an amplification of this.

But:

1. Such an inference is at best only probable. The writer of this Epistle might possibly count on his readers understanding his allusion at once to a tradition that may have been well known, while St. Jude thought it best to point out the allusion more plainly.
2. It is possible that the contest alluded to is not that between Satan and Michael about the body of Moses, but that between Satan and the angel of the Lord about Joshua the high priest (Zechariah 3:1–2).
3. It is also possible that it does not refer to any contest with Satan at all, but merely to angels not denouncing these false teachers before God, but leaving them to His judgment.

If either (2) or (3) is correct, the argument for the priority of Jude falls to the ground. If (1) is right, then the argument really favors the priority of 2 Peter. For if the author of 2 Peter had Jude before him (and this is maintained by those who contend for the priority of Jude), and wished to make use of St. Jude’s illustration, why would he so deface St. Jude’s statement of it as to make it almost unintelligible?

The reason suggested is altogether inadequate—that reverential feelings made him wish to avoid mentioning Michael’s name, a name that every Jew was perfectly familiar with from the Book of Daniel.

Greater in power and might.—This is taken in two ways—either “greater than these audacious, self-willed men,” which is the simpler and more natural explanation; or “greater than other angels,” as if it were a periphrasis for “archangels,” which is rather awkward language. But either explanation makes good sense.

Railing accusation against them.—Literally, a railing judgment. Wycliffe has “doom,” all the rest “judgment,” both of which are superior to “accusation.” “Against them,” if the reference is either to the contest about the body of Moses or to Zechariah 3:1-2, must mean against “dignities.” In this context, “dignities” must mean fallen angels, who are considered still to be worthy of reverence on account of their original glory and indefectible spiritual nature.

The position is, therefore, that what angels do not venture to say of devils—indeed, this very thing, and worse than this—these audacious men dare to say of angels and other unseen powers. But “against them” may possibly mean “against the false teachers,” i.e., they speak evil of angels, yet the angels bring no denunciation against them, but leave all judgment to God (Deuteronomy 32:35–36; Romans 12:19; Hebrews 10:30). This explanation avoids the awkwardness of making “dignities” in 2 Peter 2:10 mean unseen powers generally, and chiefly good ones, while “against dignities” in this verse has to mean against evil powers only.