2 Peter 2:11

ὅπου = “whereas”. The interpretation of this verse turns on the meaning of κατʼ αὐτῶν. Does it refer to the false teachers, or to a distinction between two sets of angels, which finds an illustration in the contest between Michael and Satan for the body of Moses? (Jude 1:9). In the latter case κατʼ αὐτῶν would refer to the fallen angels. Another possible interpretation is that ἄγγελοι ἰσχύϊ καὶ δυνάμει μείζονες ὄντες are a superior class of archangels (Spitta), and κατʼ αὐτῶν would refer to the δόξαι in general. Chase suggests that the reference is to the false teachers, and angels are represented as bringing before the Lord tidings as to the conduct of created beings, whether angels or men (op. cit. 797 b).

We may note the tendency in 2 Peter exemplified here to put in general terms what Jude states in the particular, in the story of Michael and Satan. The particulars of Jude are omitted (as also the name Enoch afterwards) in order to avoid direct reference to apocryphal writings. Accordingly the sentence, οὐ φέρουσιν κατʼ αὐτῶν βλάσφημον κρίσιν, is only intelligible by reference to Jude 1:9, where Michael does not himself condemn Satan, but says ἐπιτιμήσαι σοι κύριος. Cf. note on βλασφημοῦντες, 2 Peter 2:10.