New Defender's Study Bible Notes
20:12 the dead. The “dead” here are the unsaved dead, their bodies having been raised in the second resurrection in order to stand before God in judgment. Whether those believers who are still living in the millennial earth at this time will also be raised—along with any believers who may have died during the thousand years—is not stated, but this would be a reasonable assumption, since they also would have perished in the final holocaust if not before. In any case, their names would indeed have been “written in the book of life,” so they would not be judged with the others “according to their works.”
20:12 according to their works. When the dead are judged according to their works, they must all be sent to hell, for “there is none righteous, no, not one” and “by the deeds of the law there shall no flesh be justified in His sight” (Romans 3:10,20). Since they have rejected or ignored God’s infinite grace and Christ’s infinite love in dying for their sins, “there remaineth no more sacrifice for sins, But a certain fearful looking for of judgment and fiery indignation, which shall devour the adversaries” (Hebrews 10:26-27). Even though “God is not willing that any should perish,” His justice demands it when they intractably have refused throughout their lives to “come to repentance” (II Peter 3:9) and to personal faith in Christ.
20:13 death and hell. “Death” is often taken as synonymous with “the grave” (e.g., I Corinthians 15:55), where dead bodies are confined, whereas “hell” (Greek hades) is the place where the souls of the dead are confined. Multitudes of dead bodies are in the sea, rather than in the earth, of course, especially the great numbers of people who perished in the Noahic Flood. The ashes of those bodies that have been cremated have found their way either to the earth or to the sea, and so are also included among either the dead in the sea or those in the ground. In any case, the dead bodies of the unsaved will all be raised, presumably in their old natural condition, and reunited with their souls from Hades, to go before God in judgment.