The method of inner models, used by Gödel to prove the (relative) consistency of the axiom of choice and the generalized continuum hypothesis [2], cannot be used to prove the (relative) consistency of any statement which contradicts the axiom of constructibility (V = L). A more precise statement of this well-known fact is:

(*)For any formula θ(x) of the language of ZF, there is an axiom α of the theory ZF + V ≠ L such that the relativization α(θ) is not a theorem of ZF.

On p. 108 of [1], Cohen gives a proof of (*) in ZF assuming the existence of a standard model of ZF, and he indicates that this assumption can be avoided. However, (*) is not a theorem of ZF (unless ZF is inconsistent), because (*) trivially implies the consistency of ZF. What assumptions are needed to prove (*)? We know that the existence of a standard model implies (*) which, in turn, implies the consistency of ZF. Is either implication reversible?

From our main result, it will follow that, if the converse of the first implication is provable in ZF, then ZF has no standard model, and if the converse of the second implication is provable in ZF, then so is the inconsistency of ZF. Thus, it is quite improbable that either converse is provable in ZF.