大般涅槃經義記 1.87

1.87

問曰：如來般涅槃時，憍梵波提在天不來，何故不簡？釋言：迦葉及與阿難，今雖未至，後必當來，故此簡之。憍梵在天，畢竟不來，故今不簡。如此流例亦應非一，此第五竟。

Question: When the Tathāgata entered parinirvāṇa, Gavāmpati was in heaven and did not come; why was he not excluded? Explanation: Although Kāśyapa and Ānanda had not arrived now, they definitely would come later, so they are excluded here. Gavāmpati was in heaven and would never come, so he is not excluded now. Cases of this sort should also be more than one. This finishes the fifth.