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Other, extra theoretical arguments in opposition to encroachment have also been advanced; see for instance Ichikawa, Jarvis, and Rubin , who argue that pragmatic encroachment is at odds with essential tenets of belief-desire psychology. Another attainable line is the one mentioned in §2—to strengthen the justification situation t o rule out Gettier circumstances as justified. In order for this technique to prevent Zagzebski’s recipe from working, one would want to posit a justification condition that precludes the risk of the 1st step above—the only apparent way to do this is for justification to ivolve reality. If it does, then it's going to after all be inconceivable to begin out with a case that has justified false belief. This kind of approach is under no circumstances mainstream, however it does have its defenders—see e.g., Sturgeon 1993 and Merricks 1995. Sutton 2007 and Littlejohn 2012 defend factive approaches to justification on different grounds. In help of , Radford e