of injustice. Anglican theologian F. W. Dillistone stated that "no strictly penal theology of the atonement can be expected to carry conviction in the world of the twentieth century." Among the problems identified is that the word "penal" implies an association with law, but the relationship between theological ideas and social institutions such as the law changes. The contemporary argument as to the relationship of human rights to positive law is a modern extension of this. Secondly, ideas of justice and punishment are not the same in Jewish law, imperial Roman law, sixteenth-century European law and modern common law. Thus, for instance, "satisfaction" and "merit" are understandable within the context of Roman law, but sit less easily within either Old or New Testament conceptions. Likewise, when the word "penal" is used, it raises as many questions about the different theories of punishment, past and present. Thirdly, in Calvin's work, and subsequently, there is an interplay between legal and cultic language. Words such as "curse", "expiation", "propitiation", "wrath", and "sacrifice" appear together with sixteenth-century legal language. "The framework is legal, the process is cultic. Removal of legal sanctions is equated with freedom of access in worship." Calvin contends that it was necessary for Jesus to suffer through a judicial process and to be condemned as a criminal (even though the process was flawed and Pilate washed his hands of the condemnation), but tying this to the need for sacrifice "proved to be a dead weight upon the thinking and imagining of Reformed Christendom." according to Dillistone. Next, the two words "expiation" and "propitiation" present problems. It has been argued that the former, which means to purge away, needs to be distinguished from the latter, which means to appease a person, and that it is propitiation which presents the problem for those who are critical of the idea of penal substitution. Karl Barth (and later Jürgen Moltmann) argued in Church Dogmatics IV/1 that propitiation and expiation are false categories when applied to the triune God: If God forgives us in and through Christ ("Christ pays our debt"), then the cost has been borne by God in, as, and through Christ. For God to propitiate himself is expiation; because expiation is always self-propitiation as it means the forgiver paying the debt (here, the price of the sin) at his own expense. Hence Dietrich Bonhoeffer says grace is free, but is not cheap. Additionally,