Numbers 35:20

But if he thrust him of hatred, or hurl at him by laying of wait, that he die;

The verse describes a deliberate killing in which one person thrusts at another out of hatred or hurls at him from ambush so that he dies. Hatred and lying in wait are the marks of intent that separate willful, premeditated murder from an accidental or unwitting killing. It stands in the law of the cities of refuge, which sheltered only the unwitting slayer from private vengeance until a fair trial, while the convicted willful murderer was delivered up to be put to death. Those cities are a type of the refuge found in Christ Jesus, for as the manslayer fled to the city so the sinner who flees to Christ and remains in Him is safe, but to leave that refuge is to face wrath and judgment.

Words and Legal Setting

Numbers 35:20 belongs to the instruction about cities of refuge for manslayers, which is part of the law concerning murder given to Israel of old. In its setting it follows the journeys recorded in Numbers 33, the death of Aaron, the warning concerning the idolatrous inhabitants of Canaan, and the border of the land, and it stands with the account of Zelophehad's daughters.

The verse describes a deliberate killing in which one thrusts another out of hatred or hurls at him by lying in wait and ambushing him so that he dies. Hatred and lying in wait are the evidence of intent that distinguishes willful, premeditated murder from an accidental or unwitting killing. A thrusting or lying in wait to attack out of hatred shows intent, so that one who strikes from hatred or from ambush with intent that the person die is guilty of willful murder and not eligible for refuge as an unwitting slayer.

A city of refuge protected only the unwitting slayer, and the deliberate killing from hatred or by lying in wait is not included in that provision. The law mitigated the customary duty of the next of kin to avenge murder by sheltering the accused from private vengeance until a fair trial established guilt or innocence. It did not let a convicted willful murderer escape the legal consequences of guilt, but after a fair trial one found guilty was delivered up to be slain. A murderer convicted beyond question was to receive the death penalty, which also served to restrain future crime.

Refuge Typifying Christ

The cities of refuge appointed in the law concerning murder are a type of the refuge found in Christ Jesus. That law distinguished a killing done deliberately, through hatred or by lying in wait, from an unwitting killing, and its wider provision for the manslayer answers to the sinner fleeing to Christ. Whoever flees to Christ and remains in Him is safe from the law's demand for life, because Christ lives forever and intercedes for him.

The law established cities of refuge for one who kills another accidentally, so that the manslayer was safe from vengeance inside the city and had to remain there until the death of the high priest, while thrusting from hatred or attacking from ambush stands apart as deliberate killing in contrast with accidental manslaughter. Safety therefore depends on remaining within the appointed refuge, for Christ is the believer's refuge and to leave Him is to face wrath and judgment. The cities appointed among God's people Israel of old were true cities of safety, unlike the thoroughly fortified cities of this world that men have thought to be cities of safety.