A few notable witnesses (ℵ B W Z Δ Σ Φ f1 pc; Cl Or-pt Chr-pt) do not have the definite article before γης as most witnesses do (including D E G K L M S U Θ Π Ω f13 565 1424; Or-pt Eus Chr-pt). The fact that the expression occurs far more often with the article (i.e., επι της γης or επι την γην) than without might suggest that it was added in conformation with its more common usage elsewhere. Nevertheless, Bloomfield (Annotations, 5) remarks that the article "was doubtless removed for the sake of adaptation to εν ουρ[ανω]," which appears without the article. There is also the possibility that the three-letter word, two letters of which are identical with the three-letter word that follows, dropped out accidentally (cf. Matt 1:22 του) or even intentionally since it is unnecessary. Cf. also Matt 28:18, where a few manuscripts (B D 892 pc) add the article, perhaps in accordance with common usage, and 1 Cor 8:5, where many manuscripts do the same (probably for the same reason).
From a strictly theoretical perspective, the Byzantine-priority suggestion of the article's possible authenticity here is no different than Nestle-Aland's suggestion of its possible authenticity in Matt 28:18: the manuscripts that are deemed to be habitually more accurate on internal grounds can never easily be dismissed. Consequently, as there are internal reasons why the article could have been omitted in a few manuscripts regardless of time and place, the tentative retention of the article here in accordance with most manuscripts does not seem inappropriate.
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