A. PRINCIPLES-- NOT SPECIFIC PROCEDURES FOR INDIVIDUAL CASES
Although the Scriptures have much to say about the spiritual unity which binds all believers together in the body of Christ and with one another and despite the exhortations of the inspired writers that the church shot seek to manifest its given unity externally without endangering the means which the unity of the church is created, God's Word does not prescribe specific procedures for carrying this out in each particular case. St. Paul, example, writes to "the churches of Galatia" that he was astonished that they were "so quickly deserting Him who called you in the grace of Christ a turning to a different gospel." He says to the one who preaches a gospel contrary to that which they had received, "Let him be accursed" (Gal. 1:6). But the apostle does not tell us precisely how he dealt with these Judaizers upon his arrival in Galatia. 
Did St. Paul continue to worship with them? Did he exclude them from the Lord's Supper? And even if he had reported how he handled this situation, this would not necessarily mean that the specific procedure which he followed in this particular instance would be applicable for all times and places. We know, for example, that on one occasion St. Paul refused to compel Titus to be circumcised so that "the truth of the Gospel might be preserved" (Gal. 2:1-5). But he also reports that in a different situation he insisted on the circumcision of Timothy "because of the Jews that were in those places, for they all knew that his father was a Greek" (Acts 16:3).  The Scriptures, rather than presenting the church with specific regulations for each and every inter-Christian relationship, set forth fundamental principles which are to be applied to the unique situation in which Christians find themselves at any given point in history.
B. A BRIEF REVIEW OF THE CHURCH'S APPLICATION OF THE SCRIPTURAL PRINCIPLES OF FELLOWSHIPS
Down through the centuries, seeking to be faithful to the principles of fellowship presented in the Scriptures, Christians have developed various procedures and organizational structures which have attempted to provide orderly and helpful guidance for local congregations in their relationships with one another.
During the first four centuries of the church as Christianity spread throughout the world, it became necessary to develop ways for geographically separated congregations to advise one another regarding church membership. For the early church, church fellowship was altar fellowship, and unity in doctrine was its prerequisite.  In keeping with this understanding, circular letters were sent throughout Christendom reporting excommunications. "Letters of Commendation" and later "Letters of Fellowship" and "Letters of Peace" were "universally required of Christians in a strange place as evidence toward their reception by a new congregation or bishops." 
As a result of the Christianization of the West, membership in church was more or less taken for granted in most parts of Europe during the Middle Ages. Disruptive disagreement with the traditional teaching authority of the church resulted in excommunication. Following the Reformation, membership in Lutheran, Reformed, and Roman Catholic church was largely a matter of the faith confessed by the territorial rulers. Luther while expressly refusing to condemn "entire churches inside or outside Holy Empire of the German Nation" but "only false and seductive doctrines and their stiff-necked proponents and blasphemers" (Preface to The Book Concord, p. 11),  taught that external unity in the church was not a matter of ceremonies but of agreement "in doctrine and in all its articles" and in " right use of the holy sacraments" (FC SD, X, 31). With the rise of "denominationalism" in the 19th century, confessional Lutherans sought to apply these same Scriptural principles of fellowship through declarations of altar and pulpit fellowship with those church bodies with which they were in doctrinal agreement and by the repudiation of church fellowship with adherents of false doctrine. In recent years other models for achieving external unity in an increasingly splintered Christendom have been advocated.
In an attempt to provide guidance to the Synod today as it relates other church bodies, we shall examine three of these proposals which, more frequently mentioned in addition to the more traditional ecclesiastical declaration of altar and pulpit fellowship, and evaluate them on the basis the Scriptural principles of fellowship presented in the first section of this report. 
Conciliarity or conciliar fellowship refers to the model for church unity which has been promoted by the World Council of Churches. Serious consideration of church unity has taken place in the WCC ever since its formation in 1948.  In 1957 the Faith and Order Commission initiated a study on "The Nature of the Unity We Seek." The New Delhi Assembly of the WCC in 1961 spoke of the nature of the unity for which the member churches of the WCC should strive in terms of a visible unity of "all in each place" in "a fully committed fellowship. "  The term "conciliar" was first used by the Uppsala Assembly in 1968 when it spoke of "eventually actualizing a truly universal, ecumenical, conciliar form of common life and witness. " Conciliarity as the World Council of Churches' model for unity in the church was given definitive form in the report of a consultation convened by its Faith and Order Commission to discuss "concepts of unity and models of union" in Salamanca in September 1973. 
Having noted that "Jesus Christ founded one Church," the Salamanca Report says that "today we live in diverse churches divided from one another." Consistent with this view, it proceeds to speak of "a united Church" as a "vision" and as a "goal" to be achieved at some point in the future as follows:
The one Church is to be envisioned as a conciliar fellowship of local churches which are themselves truly united. In this conciliar fellowship each local church possesses, in communion with the others, the fullness of catholicity, witnesses to the same apostolic faith and therefore recognizes the others as belonging to the same Church of Christ and guided by the same spirit. 
According to this report, the word "conciliar" refers "to the mutual relationships of local churches within the one Church." Stating the "conciliar fellowship requires organic union," many advocates of the World Council's model for external unity in the church have expressly rejected t? idea that "reconciled diversity" can serve as a model for the "shape of the unity" to be sought. 
Advocates of conciliarity recognize that unity in the church demands certain amount of consensus. "Fellowship will only last if it shares certain articulated forms of expression."  But this should not be understood implying a need for agreement in "a complete statement of faith." On the contrary, consensus "can be confined to a few fundamental affirmation provided it is relevant to present conditions."  This means that "the traditional expressions of our identity as confessions and communions" must be recognized as "time- bound in their terms of reference and relevance." 
The divided churches" readiness to surrender their traditional identity can be assisted by recognizing that "the criteria for establishing unity are not fixed in advance."  The Salamanca study document says that recent New Testament scholarship has contributed to the possibility of achieving this kind of consensus by demonstrating that there was far greater diversity in the early church than had generally been supposed at the beginning of the ecumenical movement. 
In recent years the question has been raised ever more insistently as to whether the New Testament really contains a concept of unity. At first the churches assumed that it did. Each was convinced that its own concept of unity was derived from the New Testament or, at any rate, could be substantiated from the New Testament. They also agreed that they must all submit themselves and their concepts to the judgment of Holy Scripture and they expected that one correct concept of unity would emerge from this confrontation with the Bible. They soon discovered, however, that their different concepts all represented contractions of the witness of Scripture. They realized that the claims of the other churches were not altogether unfounded. 
Conciliarity, therefore, in addition to demanding organic unity, embraces a unity in diversity which includes doctrinal pluralism.
How does conciliarity as a model for external unity in the church stand up when measured by the Scriptural principles of fellowship? On the positive side, it should be recognized that this proposal is to be commended for its attempt to pursue the Biblical mandate to seek external unity in the church. The Scriptures clearly teach that it is God's will and command that those who are one in Christ should seek to manifest their spiritual unity in His body externally (Thesis 9). At the same time, it must also be stated that this proposal, failing to distinguish clearly between spiritual fellowship and church fellowship, does not take seriously either the unity of the church which is given with faith (Thesis 1) or external unity in the church which constituted by agreement in confession (Thesis 7). As a result the advocate of this model frequently give the impression that Christians can actual effect the spiritual unity of the church through their own efforts toward organic union. In addition conciliarity, based on a doctrinal pluralist resulting from the forfeiture of the normative authority of Holy Scripture (Thesis 3), comes into direct conflict with the Scriptural exhortations for Christians to seek the edification of the members of Christ's body by confessing the faith in accordance with God's Word (Thesis 6). The Scriptures condemn all attempts to achieve external unity in the church by compromising the prophetic and apostolic witness through which the Holy Spirit works to create the unity of the church as a violation of the law of Christian love (Thesis 5).
Just as conciliarity has come to be identified with the World Council of Churches, so reconciled diversity is the model for external unity in the church which is generally thought of in connection with the Lutheran World Federation and the other confessional groupings of churches. This model is described in a discussion paper on "The Ecumenical Role of the World Confessional Families in the One Ecumenical Movement" which was discussed at a 1974 meeting of the Conference of Secretaries of World Confessional Families. 
The advocates of reconciled diversity, referring to the "acceptance of one another not only as individuals, but also in our different traditions and confessions" as a "fundamental insight of the ecumenical movement," maintain "that fidelity to truth as perceived by individual confessions is not incompatible."  Although the church of Jesus Christ is "by definition confessing Church with its identity grounded in him who is confessed as Lord," this confession "is expressed incompletely in the different confessional identities of the world families of churches."  It is a mistake, according to the report of the World Confessional Families, to equate confessional identity with an anti-ecumenical stance. To expect "some kind of uniform ecumenical Christian theology and culture to emerge in a uniform pattern would be to deny the multiplicity of the gifts of the Spirit and the manifold variety of creation and history."  This report continues:
We consider the variety of denominational heritages legitimate insofar as the truth of the one faith explicates itself in history in a variety of expressions. We do not overlook the fact that such explications of the faith have been marked by error which has threatened the unity of the Church. On the other hand, it needs to be seen that a heritage remains legitimate and can be preserved, if it is properly translated into new historical situations. If it is, it remains a valuable contribution to the richness of life in the Church universal.
In the open encounter with other heritages the contribution of a particular denomination can lose its character of denominational exclusiveness. Therefore, unity and fellowship among the churches do not require uniformity of faith and order, but can and must encompass a plurality or diversity of convictions and traditions. . . . Confessional localities ecumenical commitment are no contradiction, but are one -- paradoxical as it may seem. When existing differences between churches lose their divisive character, a vision of unity emerges which has the character of a "Reconciled diversity." 
The conclusion of this way of thinking, therefore, is that it is not organic unity but "'reconciled diversity,' which acknowledges under the Gospel that the things of the faith which unite are greater than those that separate," which offers the most appropriate model of achieving external unity in the church today. 
Bishop Andreas Aarflot from Norway has encouraged the Lutheran World Federation to pursue the goal of "reconciled diversity" in its quest for external unity in the church. In an essay he presented to the sixth assembly of the LWF in Dar-es-Salaam in 1977, Bishop Aarflot asks the question: "What kind of unity do we seek?"  In answering this question, Aarflot takes up what he calls "two tendencies within the ecumenical movement": "organic union" as the attempt to unite churches of different confessional traditions "in such a way that they surrender their previous confessional identity in order to constitute a new church with new norms and new identity" and "reconciled diversity" as "an ecumenical fellowship in which each confessional heritage and confessional identity is still maintained."  Contending that both of these models "are lacking in clarity and explicitness," he concludes that "the idea of unity as 'reconciled diversity' can still be of some help, as long as it is purified and critically examined diversity, since it describes a way of unity which does not automatically entail the surrender of confessional traditions and confessional identities."  Aarflot continues:
This way to unity is a way of living encounter, spiritual experience to-tether, theological dialogue and mutual correction, a way in which the distinctiveness of each partner is not lost sight of but stands out, is transformed and renewed, and in this way becomes visible and palpable to the other partners. There is no glossing over differences. Nor are the differences simply preserved and maintained unaltered. But they lose their divisive character as they are reconciled to each other. 
Bishop Aaarflot strongly emphasizes the element of reconciliation. "Unity and reconciliation do not mean mere coexistences" but "genuine church fellowship, including as its essential elements the recognition of baptism, pulpit and altar fellowship, the mutual recognition of church ministries, and a binding common purpose of witness and service." 
Although differences exist between conciliarity and reconciled diversity as models for implementing external unity in the church, they share the same basic strengths and weaknesses with respect to the Scriptural principles of fellowship. Like conciliarity, reconciled diversity rightly emphasizes the Scriptural exhortations for Christians "to maintain the unity of the Spirit in the bond of peace" (Thesis 9).  But despite a greater awareness by those who advocate reconciled diversity that "certain elements of common Christian understanding are indispensable for the true unity of the church" (Thesis 6), and that "we must . . . carry the burden of separation wherever this is necessary in order to witness to the truth of the gospel" (Thesis 8),  in the final analysis this model for external unity in the church is founded on the unscriptural notion that church fellowship can be based on agreement in the Gospel in the narrow sense while tolerating disagreement in other doctrines taught in the Scriptures (Thesis 7).  Like "the lowest common denominator" approach of conciliarism, so the "agreement to disagree" model of reconciled diversity violates the law of Christian love through its willingness to practice "genuine church fellowship" where there is disagreement "in doctrine and in all its articles" and in "the right use of the holy sacraments" (Thesis 5).
There is a troublesome ambiguity about reconciled diversity as a model for effecting external unity in the church. As the Rev. John Gatu, general secretary of the Presbyterian Church of East Africa, stated in his response to Bishop Aarflot's address to the LWF assembly: "My problem . . . is that the speaker expects a perpetuation of a Lutheran identity in the organic union. That of course is tantamount to saying that the only way to church unity is for all of us to become Lutherans!"  Reconciled diversity either has no theological reason for preserving the identity of the individual confessional families in that it is genuinely willing to tolerate doctrinal pluralism, or it implicitly suggests the superiority of one confessional position over the other, a stance which is offensive to Christians belonging to other confessional families who are expected to be a part of this external unity of reconciled diversity. Each of these viewpoints compromises certain of the Scriptural principles of fellowship.
Selective altar and pulpit fellowship is sometimes proposed as a model for external unity in the church. The 1946 convention of the former American Lutheran Church, for example, adopted a resolution calling for the practice of selective fellowship.  Memorials requesting that The Lutheran Church--Missouri Synod permit selective fellowship have been submitted to each of the last seven conventions of the Synod.  In addition, a number of responses to the CTCR's "Bible Study on Fellowship" have also suggested that the Synod adopt this way of relating to other Christian churches. It is argued that since differences within church bodies are often as great as those dividing denominations, selective fellowship offers a model for the practice of church fellowship which is faithful not only to the Scriptural mandate to preserve the truth of God's Word but also to the apostolic exhortations to manifest love for all fellow members of Christ's body, no matter where they may be located. But what is selective fellowship?  The answers to this question are almost as numerous and varied as those who propose it as a model for working toward external unity in the church. There are those who regard selective fellowship as a church body's decision to allow each of its local congregations to decide on whether or not to engage in altar and pulpit fellowship with a congregation of another church body on the basis of a repudiation of the false doctrine(s) officially held by the denomination to which it belongs.  Some, thinking of church fellowship as being constituted by faith in the heart (fides qua), advocate this model because they believe that the local congregation is in a better position than synodical conventions to recognize with which members of other denominations its members are already in fellowship by virtue of their common faith in Jesus Christ.  Still others regard selective fellowship as a model for external unity in the church which provides an opportunity for Christians at the local level to give expression to their unity in Christ despite their differences in doctrine. 
It is not necessary to attempt to describe here each and every variation of this model. Quite obviously, different forms of selective fellowship come into conflict with different principles of fellowship. A selective fellowship, for example, which would base altar and pulpit fellowship on faith in the heart confuses spiritual fellowship in the body of Christ (Thesis 1) and church fellowship (Thesis 7).  Congregational decisions to engage in altar and pulpit fellowship despite differences in doctrine violate the divine mandate to confess the faith as it is taught in the Scriptures for the sake of the edification and extension of the church (Thesis 6). But in view of the general confusion surrounding the meaning of selective fellowship and taking into account the high mobility of both lay people and clergy in a time when the theological positions of pastors and congregations of even the same denomination vary so greatly, all forms of selective fellowship, including that which would base congregational altar and pulpit fellowship on agreement in doctrine, must be regarded today as falling short of fulfilling the law of Christian love which seeks the edification of Christ's body (Thesis 5). Selective fellowship not only provides an opportunity for offense by appearing to be indifferent to doctrine, but it is also inherently conducive to chaos, confusion, individualism, and even rebellion.  Moreover, as Hermann Sasse has emphasized, it is "impossible to separate the fellowship between local churches from the fellowship between the church bodies to which they belong." 
4. Ecclesiastical Declaration of Altar and Pulpit Fellowship
From the very beginning of the Reformation Luther and his followers sought external unity in the church on the basis of agreement in the confession of the apostolic faith. Expressing the hope that they might be "united in one, true religion" with their opponents "even as we are all under one Christ," the Lutherans in 1530 in Augsburg presented "a confession of our pastors' and preachers' teaching and of our own faith, setting forth how and in what manner, on the basis of the Holy Scriptures, these things are preached, taught, communicated, and embraced in our lands" (Preface to the Augsburg Confession, 8-10). They also participated in a variety of doctrinal discussions with leaders of the Reformed Church, e.g., in Marburg in 1529. Their concern was not "that ceremonies, instituted by men, should be observed uniformly," but that "the Gospel be preached in conformity with a pure understanding of it and that the sacraments be administered in accordance with the divine Word" (AC, VII, 2-3). Altar and pulpit fellowship apart from agreement in doctrine was unthinkable for them. 
In the years following the settlement of the serious doctrinal disputes which arose in the wake of Luther's death, church fellowship among the various territorial churches (the European nations in which Lutherans lived were divided into territories, with each one having its own church) was achieved by agreement with the confessional writings in The Book of Concord (1580). Subscription to these confessions, understood by all to be a binding commitment to the entire doctrinal content of these writings, meant that pastors were allowed in each other's pulpits and that lay people were welcomed at each other's altars 
With the passing of time and as a result of the coming of Lutherans to America, however, problems concerning church fellowship arose. In the absence of the territorial churches, ecclesiastical structures such as ministeria (organizations of ministers) and synods (organizations of congregations together with their pastors) were developed. Concerned about external unity in the church, these new churches had to answer the question regarding church fellowship with one another as well as with the growing number of other denominations present on the American scene. Free conferences for the purpose of discussing doctrine were held.  These discussions revealed that many of these new churches were divided not only by language, national origin, and church polity but also by doctrinal differences resulting from the various rationalistic, pietistic, and confessional circles out of which they had originated in Europe. Moreover, it soon became quite obvious that Lutherans were no longer in agreement regarding the meaning of subscription to the Lutheran Confessions.  Altar and pulpit fellowship, therefore, could not be established among all of these young churches. But the very fact that doctrinal discussions were held and that there was a general consensus that some kind of identification with at least the Augsburg Confession was necessary for the celebration of church fellowship illustrates that 19th-century Lutherans in America generally followed the model of ecclesiastical declarations of altar and pulpit fellowship on the basis of agreement in doctrine at the church-body level. 
The Lutheran Church--Missouri Synod, in accordance with this historical Lutheran precedent, has consistently followed this model with respect to its official relationships with other church bodies. Desiring to avoid both sectarianism or separatism  as well as syncretism or unionism,  it has sought external unity in the church through the use of the model of ecclesiastical declarations of altar and pulpit fellowship based on agreement in doctrine and practice. From the time of its origin in 1847, the Synod has always insisted on formal doctrinal discussions with another church body prior to establishing altar and pulpit fellowship with it. Discussions between official representatives from each church body are carried out on the basis of the following principles:
1. That the Confessions must be subscribed to quia, not quatenus, i e., because, not merely insofar as, they are correct expositions of the Scripture;
2. That all doctrines taught in the Confessions are binding;
3. That subscription to the Confessions must be implemented by corresponding public teaching (publica doctrina) in pulpit, instruction room, seminary, and in the church's publications, and that all who departed from this norm were to be disciplined. 
It was on the basis of these principles that the Missouri Synod participated in the free conferences which took place during the last half of the 19th century and that it declared altar and pulpit fellowship with other Lutheran synods and was instrumental in organizing the Evangelical Lutheran Synodical Conference of North America in 1872.  These principles also manifest themselves in the long history of doctrinal discussions which took place with The American Lutheran Church (and its predecessor bodies) prior to the declaration of altar and pulpit fellowship with this church body by majority vote at the 1969 convention of the Synod.
The practical implications of a declaration of altar and pulpit fellowship with another church body are set forth in the resolution in which the LCMS declared altar and pulpit fellowship with The ALC.  First noting that "with the establishment of fellowship each church body retains its separate identity and organizational structure, procedures, and policies," this resolution holds that "a congregation of one church body may call as its pastor a clergyman of the other church body, provided that prior consultation has resulted in mutual approval by the respective administrative officials of both church bodies involved in such a call." This document then proceeds to state that altar and pulpit fellowship will express itself in the following ways:
1. Pastors in good standing in each church body may be invited to preach from the pulpits of congregations of the other church body.
2. Congregations of church bodies in fellowship may hold joint worship services.
3. Members of the congregations of each church body who are in good standing in their own congregation and do not violate principles regulating Communion practices in the host congregation shall be welcome guests at the altar of congregations of the other church body. In the interest of the pastoral care and responsibility of the congregation of which an individual is a member, there should not be an indiscriminate visiting of the altars of churches either within his own church body or at the altars of congregations of that church body with which his church is in fellowship.
4. Members in good standing may transfer their membership from a congregation of one church body to a congregation of the other church body in conformity with the practices of the receiving congregation.
These provisions make it clear that the Synod regards altar and pulpit fellowship to be an alternative to organic merger as an acceptable way of satisfying the divine mandate that the members of the body of Christ seek to manifest their unity externally. 
This model of ecclesiastical declaration of altar and pulpit fellowship does not in and of itself stand in conflict with any of the Scriptural principles of fellowship set forth in the first section of this report. On the contrary, with its insistence that external unity in the church be based on agreement in doctrine and practice, for example, this model allows for making a clear distinction between spiritual unity in the body of Christ, which is given with faith (Thesis 1), and external unity, which is constituted by agreement in the faith which is confessed for the sake of the unity of the church (Thesis 7).  By making the declaration of altar and pulpit fellowship dependent on the prior assurance that agreement in doctrine and practice actually exists between the church bodies involved, it takes seriously the divine mandate that the faith be confessed in accordance with the Scriptures for the sake of the edification and extension of Christ's body, the church (Thesis 6). It is in this way that this model seeks to guard against the loveless toleration of any compromising of the Gospel through which the spiritual unity of the church comes into being (Thesis 8). And by requiring that the declaration of church fellowship be a church-body decision rather than merely a congregational decision, it seeks to minimize the danger of being misled by a false witness of external unity where agreement in confession does not in fact exist (Thesis 5).
In the first part of this report the Commission on Theology and Church Relations has attempted to present the nature of fellowship on the basis of a review of what God's Word has to say about this concept. Our study has reached the conclusion that in the Scriptures fellowship is understood in the sense of its root meaning as having part in a common thing.  Contrary to the understanding of fellowship prevalent in Christendom today as relating to "matters about which men are free to make their own arrangements" and that "whether fellowship is granted or withheld depends on the good or ill will of those concerned,"  the writers of the New Testament use this term to refer both to spiritual unity in the body of Christ and to external unity in the church. Each of these relationships, therefore, may properly be referred to by the use of the English word "fellowship." But neither of them is the result of human achievement, nor "are they matters about which people are free to make their own arrangements."
Christians are not in spiritual fellowship with their Lord and with each other in the body of Christ because they have voluntarily decided to "get together." God's holy Word reveals that believers are brought into a spiritual relationship with Christ and with all fellow believers by virtue of their incorporation into the body of Christ by the power of the Holy Spirit working through the means of grace. Having been made one in Christ, members of His body are exhorted to be what they are. Christians therefore seek to be faithful to what the Scriptures teach about manifesting their unity in Christ externally. Forbearing one another in love, they are eager to maintain the unity of the Spirit in the bond of peace on the basis of agreement in the confession of the faith through which they have already been made one in Christ.
The Scriptural Gospel is the voice of Jesus Christ, the Good Shepherd who laid down His life for His sheep. Since this Gospel is the means through which Christ calls, gathers, and keeps His flock in the one true faith, God has commanded the church to preserve the truth of His Word. Error in doctrine threatens unity in the body of Christ. Christian love, therefore, requires members of Christ's body to admonish and even to separate themselves from those who compromise or distort the Scriptural Gospel. "Speaking the truth in love" (Eph. 4:15), members of the body of Christ seek external harmony in the church by following "the pattern of the sound words" which they have learned from the prophets and apostles and by guarding "the truth that has been entrusted" to them "by the Holy Spirit who dwells within" them (2 Tim. 1:13-14). They desire to be faithful to the apostolic injunction "that all of you agree and that there be no dissensions among you, but that you be united in the same mind and the same judgment" (1 Cor. 1:10).
In the second part of this report the Commission has discussed the implications of this understanding of the nature of fellowship for church body-level relationships by reviewing four contemporary proposals for seeking to manifest external unity in the church. Three of these models have been shown to conflict in one way or another with certain aspects of the nature of fellowship as it is presented in the Holy Scriptures. Conciliarity, reconciled diversity, and selective fellowship all violate at least some of the principles of fellowship and cannot therefore be regarded as viable models for interchurch relations at the church-body level today.
Of those models for external unity in the church which have been examined in this report, only ecclesiastical declarations of altar and pulpit fellowship offer at least the possibility for being able to take into account all of what the Scriptures have to say about the nature of fellowship. The Commission on Theology and Church Relations, therefore, while recognizing that this model is neither divinely ordained nor Scripturally mandated, is convinced that The Lutheran Church--Missouri Synod should continue to seek to carry out the Scriptural principles of fellowship at the church-body level by means of ecclesiastical declarations of altar and pulpit fellowship based on agreement in doctrine and practice. 
In making this recommendation, however, the Commission also finds it necessary to point out that the adoption of ecclesiastical declarations of altar and pulpit fellowship is by itself no guarantee of a church body's automatic faithfulness to the Scriptural principles of fellowship. Two church bodies, for example, may formally agree in a confession of faith which compromises the Holy Scriptures as the only norm of the Gospel (Thesis 3). An overemphasis on the spiritual unity of the church can serve to obscure the Scriptural mandate to seek to manifest this unity externally (Thesis 9). A loveless "concern for the truth" and a pharisaical pride in the rightness of doctrine, which tears down rather than edifies the body of Christ, can develop (Thesis 5).
Moreover, the Commission is also aware that there are certain problems, such as fellowship triangles,  which can and do arise with the implementation of this model. It may even happen occasionally, in this age of "ambiguous denominationalism," that an individual congregation may temporarily find itself to be in closer doctrinal agreement with a congregation belonging to a church body with which it is not in altar and pulpit fellowship than it is to a sister congregation in its own synod. It is also happening with increasing frequency (as a result of the high mobility that characterizes life in our society) that individual church members find themselves moving their membership back and forth between church bodies not in altar and pulpit fellowship with one another, with the result that any number of special problems arise. There is the problem of terminology and levels of agreement. Through the use of the word "fellowship" almost exclusively to refer to a formal altar and pulpit fellowship relationship established between two church bodies on the basis of agreement in the confession of the faith, some have been given the impression that no fellowship relationship other than spiritual unity in the body of Christ can or should exist among members of Christian churches not in altar and pulpit fellowship. The fact that the LCMS is closer doctrinally to a church body which at least formally accepts the Scriptures and the Lutheran Confessions than to those denominations which do not is often obscured by the "all or nothing" approach that frequently accompanies ecclesiastical declarations of altar and pulpit fellowship. Finally, it is sometimes overlooked that, although the Scriptural principles of fellowship remain constant, the specific results of their application at the individual level may differ from that at the church-body level. The principles of fellowship are not rules of casuistry.
Because of these factors the Commission recommends that the Synod continue to study the topic of fellowship during the coming biennium by giving special attention to the implications of the principles of fellowship presented in this report for relationships and activities between Christians at the congregational, pastoral, and individual levels. Although it is neither desirable nor even possible to develop guidelines which will answer every case of casuistry, it will be helpful if the Synod can develop greater understanding and consensus regarding the implications of the nature of fellowship also at these levels.
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