In Grunbaum (1989, 374, 390), I objected to Narlikar's (1977, 136-137) designation "event of 'creation'" for a supposed first cosmic instant t = 0, which he imports into the big bang cosmology of the general theory of relativity (GTR). Narlikar (1992, 361-362) does reject a theological construal of the "creation". But, endeavoring to justify his secular creationism, he now points out that, in the GTR, the usual derivation of matter-energy conservation from Hilbert's stationary action principle cannot be extended to include (...) the putative first instant t = 0. Narlikar reasons that this "breakdown" in the derivation of energy conservation at t = 0 qualifies the putative initial event as the "creation event". I argue that this inference is multiply fallacious. (shrink)