theology was dismissed due to controversy over his teaching on justification. His views involved a reconfiguration of covenant theology that went beyond those of Murray, his predecessor. Shepherd denied any notion of a works or merit principle, leading to a denial of the imputation of Christ's active obedience to the believer. He argued that Jesus' own justification was due to His faith and obedience. In the same way then, the believer must be justified before God by faith and obedience. Shepherd's followers claim that the Covenant of Works between Adam and God in the Garden of Eden was not originally part of covenant theology, following John Murray's observation that a covenant of works at creation does not receive explicit mention in early confessions such as the French Confession (1559), the Scots Confession (1560), the Belgic Confession (1561), the Thirty-Nine Articles (1562), the Heidelberg Catechism (1563), and the Second Helvetic Confession (1566). Some of Shepherd's critics contend that the concept of a works principle distinct from a Covenant of Grace is evident in the commentaries and dogmatic works of the earliest covenant theologians, particularly in the distinction made between Law and Gospel (for instance, Zacharias Ursinus, Commentary on the Heidelberg Catechism). There is also explicit articulation of a Covenant of Works in the writings of those such as Olevianus and Rollock. Additionally, defenders of the merit-based view argue that the concept of this works principle operating in the pre-Fall state in the Garden of Eden as a covenant is present in the early confessions even if the Covenant of Works is not explicitly named. Examples include Belgic Confession, article 14, which speaks of Adam having received and transgressed the "commandment of life"; or Heidelberg Catechism, Question and Answer 6 affirming the goodness of man in creation. The later Westminster Confession of Faith (1646) explicitly names the Covenant of Works which Adam transgressed (7.2; 19.1), and which "continues to be a perfect rule of righteousness" in the form of the moral law (19.2, 3). Kline In opposition to the modern revisers, Meredith Kline reemphasized the idea of a covenant of works as expressed in the Westminster Confession of Faith 7.2 as a means to protect a gospel of grace. Kline writes: Kline, Michael Horton, and others have sought to uphold the distinction of two sorts of covenant traditions: one based on merit, earned by obedience to law (works), and the other on