Shulchan Arukh, Orach Chayim 106:2-107:2

Sugya Map

The text in Orach Chayim 106:2 through 107:2 navigates four primary sugyot concerning the obligation, prioritization, and limits of Tefillah (prayer), establishing the fundamental contours of Avodat HaLev (service of the heart) within the structure of Halakha.

Issue	Nafka Mina(s)	Primary Sources
I. Status of Tefillah & Women’s Obligation	Whether Tefillah is defined as Mitzvat Aseh ShehaZman Grama (ZM"G) or SheLo HaZman Grama (Shl"Z"G). The root debate concerning the D'Oraita (Biblical) or D'Rabanan (Rabbinic) status of fixed prayer.	Berakhot 20b; Sukkah 25a; Rambam, Hil. Tefillah 1:1; Ramban, Shoresh 1; SA OC 106:2; Turei Zahav 106:2.
II. Hierarchy of Talmud Torah vs. Tefillah	When must one interrupt specialized Torah study (Torato Umanuto) for Kri'at Shema vs. Tefillah. The definition of Torato Umanuto.	Eruvin 13b; SA OC 106:3; Rema OC 106:3.
III. S'fek Tefillah and Tefillat Nedavah	The rule for repeating the Amidah when in doubt (safek) of the original performance, and the conditions for offering a voluntary prayer (Nedavah).	Yoma 87b; Berakhot 20b; SA OC 107:1.
IV. Definition and Limits of Chiddush	What constitutes a sufficient "innovation" (Chiddush) to transform an otherwise forbidden repeated prayer into a permissible Nedavah. Restrictions on Nedavah on Shabbat and Musaf.	SA OC 107:2; Rema OC 107:2; Rosh, Berakhot 3:3; Tur OC 107.

Text Snapshot

The core of the analysis hinges on two sections: the justification for women's obligation and the requirement for innovation in voluntary prayer.

Orach Chayim 106:2 (The Foundation of Obligation)

נשים ועבדים, אע"פ שהם פטורים מקריאת שמע, חייבים בתפלה, מפני שהיא מצות עשה שלא הזמן גרמא.

Translation: Women and slaves, even though they are exempt from the Recitation of the Shema, are obligated in [the Amidah] prayer, because it is a positive mitzvah that is not limited by time.

Dikduk/Leshon Nuance: The S.A. here uses the standard halakhic classification (Mitzvat Aseh Shl"Z"G) as the reason for women's obligation. This is a critical point of friction, as the Gemara (Berakhot 20b) appears to root the obligation in Rachamim (requests for mercy), not strictly in the Shl"Z"G principle. The choice of lesho by the Mechaber (R. Yosef Karo) signals an alignment with a specific Rishon (likely the Rambam, as the Magen Avraham notes[^1]) who views the core Mitzvah as non-time-bound, despite the fixed D'Rabanan times.

Orach Chayim 107:1 (The Limits of Voluntarism)

אם נסתפק לו אם התפלל, חוזר ומתפלל ואינו צריך לחדש דבר. אבל אם ברור לו שהתפלל, אינו חוזר ומתפלל בלי חדוש. ועל ידי חדוש מותר לחזור ולהתפלל נדבה כמה פעמים שירצה, חוץ מתפלת מוסף, שאין מתפללים אותה נדבה. ובשבת ויום טוב אין מתפללין נדבה כלל.

Translation: If one is in doubt if one prayed [the Amidah], one goes back and prays [the Amidah again], and one does not need to innovate anything new. But if it clear to one that one prayed, one does not go back and pray [again] without an innovation. And by means of [using] an innovation, one may return and pray as a voluntary [Amidah] as many times as one wants, except for the Musaf prayer, for we do not pray it as a voluntary [Amidah]. And on Shabbat and Yom Tov, one may not pray a voluntary prayer at all.

Dikduk/Leshon Nuance: The language distinguishes sharply between Safek (doubt), which defaults to Chiyuv (obligation) and requires no Chiddush, and Vaday (certainty), which defaults to Nedavah (voluntarism) and requires the Chiddush. The immediate restriction of Musaf and Shabbat/Yom Tov establishes that the capacity for Nedavah in Tefillah is not limitless; it is bounded by the nature of the specific prayer and the sanctity of the day.

Readings

The ensuing lomdus revolves around the dual nature of Tefillah: Is it a fixed decree (Chova) or an open-ended act of service (Avodat HaLev)? The tension between these concepts governs the obligation of women and the permissibility of repeated prayer.

Rambam: Tefillah as a D’Oraita Imperative

The Rambam (Maimonides) provides the foundation for the S.A.'s structure in OC 106:2 by asserting that the obligation of Tefillah is fundamentally D'Oraita (Biblical).

The Essence of Avodat HaLev

The Rambam argues that the positive commandment is derived from the verse: "and to serve God with all of your heart" (u'le'ovdo b'chol levavkhem - Deut. 11:13). He famously interprets "service of the heart" (Avodat HaLev) as Tefillah.[^2] Crucially, he holds that this D'Oraita obligation is simple: to pray once daily, using any formulation of praise and request (shevach, bakasha, hoda'ah), at any time.

Implication for Shl"Z"G

Since the D'Oraita command is fulfilled by praying once daily, without fixed times or form, the Rambam views the root Mitzvah as SheLo HaZman Grama (Shl"Z"G). The fixed times (Shacharit, Mincha) and formulations (the 18 blessings) are merely Takkanot (enactments) of the Sages (Anshei Knesset HaGedolah). Because women are obligated in all Shl"Z"G positive commandments, they are obligated in the Tefillah as a D'Oraita Mitzvah. The Sages, in turn, extended the D'Rabanan fixed times to them because the core obligation already existed. This reading provides the strongest support for the S.A.'s explicit statement that women are obligated "because it is a positive mitzvah that is not limited by time" (SA 106:2), as noted by the Magen Avraham[^3] and Ba'er Hetev[^4].

Practical Kula for Women

The Mishnah Berurah, synthesizing the Acharonim, notes a significant practical nafka mina arising from the Rambam's view: many women traditionally relied on this D'Oraita minimum. Since the Biblical requirement is satisfied by reciting any request daily, many women fulfilled their obligation simply by reciting a short prayer upon awakening or washing their hands. The Magen Avraham observes that "most women have the practice of not praying regularly" (b'tmidut) because they satisfy the D'Oraita requirement with a short request, and the Sages might not have extended the full D'Rabanan framework upon them.[^5] While the Psak ultimately leans toward the Ramban (below), the Rambam’s structure provides the halakhic bedrock for this minhag.

Ramban: Tefillah as a D’Rabanan Requirement of Rachamim

The Ramban (Nachmanides) vehemently rejects the Rambam’s assertion that fixed, daily Tefillah is D'Oraita.

The Origin of Fixed Prayer

The Ramban argues that the only D'Oraita obligation related to prayer is the requirement to cry out to God during times of immediate distress or war (derived from Deut. 4:7). Fixed, daily prayer, however, is purely a Takkanah instituted by the Anshei Knesset HaGedolah—making it D'Rabanan.[^6] This view is accepted by most Rishonim and is considered the consensus opinion (Divrei Rov HaPoskim).

Overriding ZM"G via Rachamim

If Tefillah is D'Rabanan, and fixed prayers occur at fixed times (Shacharit, Mincha), they should technically be ZM"G, thus exempting women. The Ramban, following the explicit Gemara (Berakhot 20b), resolves this paradox by asserting that women are obligated not because Tefillah is Shl"Z"G, but because Tefillah is fundamentally Rachamim (a request for mercy). The Turei Zahav (TaZ) highlights this exact conflict, noting that while Tosafot might justify the S.A.'s Shl"Z"G language, Rashi and others simply hold the reason is Rachamim.[^7]

The logic of Rachamim dictates that since women require divine mercy (for health, sustenance, children, etc.) just as much as men, they cannot be exempted from the means by which that mercy is sought. This Chiddush (novelty) is that the nature of the Mitzvah (a universal, necessary request for sustenance/mercy) overrides the general rule of ZM"G exemption for D'Rabanan commandments. The Mishnah Berurah ultimately adopts this view as the primary Psak: "And this is the essence, for this is the opinion of most decisors, and the Sefer She’agat Aryeh also ruled thus."[^8]

Rosh: The Avodat HaLev Basis for Nedavah

Rabbenu Asher ben Yechiel (Rosh) focuses on the logical permissibility of Tefillat Nedavah (voluntary prayer) in OC 107:1, grounding it in the unique nature of Tefillah as Avodat HaLev.

Tefillah as Unbounded Service

The Gemara (Berakhot 21a) asks: How can one pray a Nedavah? Repeating an obligatory prayer seems to imply taking God's name in vain or challenging the fixed structure. The Rosh explains that Tefillah is fundamentally different from other Mitzvot. Unlike Tefillin or Sukkah, which are concrete actions performed once to fulfill a defined obligation, Tefillah is an internal state of devotion and connection. It is the service of the heart.

The Rosh argues that Avodat HaLev is an unbounded commitment; one can always increase one's devotion and requests for mercy.[^9] Therefore, a Nedavah is not a repetition of the Chiyuv (obligation), but an entirely new, voluntary act of elevated service. This Chiddush explains why Safek Tefillah (doubt) is resolved by simply repeating the original Tefillah (as an obligation), while Vaday Tefillah (certainty) requires the Chiddush to signal the transition from mandatory fulfillment to voluntary devotion.

Defining the Necessary Chiddush

The S.A. (107:2) stipulates that the Chiddush must be an innovation in the content of the middle blessings. The Rema, citing the Tur in the name of the Rosh, adds a layer of stringency: "And there are those who say that it's not called 'an innovation' unless something was added into it that one did not need beforehand."[^10] This implies a higher threshold than just slightly shifting the wording; it must introduce a novel personal request or theological insight that was genuinely absent in the initial prayer. This ensures that the Nedavah truly reflects a desire for increased service, rather than a robotic repetition of the Chiyuv.

Rema and the Hierarchy of Talmud Torah

The Rema's gloss on OC 106:3 addresses the prioritization of Talmud Torah over Tefillah, based on the famous dispute in Eruvin 13b regarding Rabbi Shimon bar Yochai (RSB"Y).

RSB"Y’s Extremity

The underlying Gemara states that RSB"Y and his companions—those whose Torah is their Umanuto (profession)—would interrupt their studies only for Kri'at Shema (accepting the yoke of Heaven), but not for Tefillah. The Rema clarifies the Psak: we do interrupt for both Shema and Tefillah. The position of RSB"Y is understood as an exceptional state where the intensity and purity of their Torah study was deemed equivalent to or superior to performing all Mitzvot (Eruvin 13b).

The Rema’s Practical Caveats

The Rema, citing the Beit Yosef (and Ran), introduces crucial practical distinctions based on time constraints:

1. Teaching Others: If one is actively teaching others, one does not interrupt for the full Tefillah (or even Shema), though one should recite the first verse of Shema (Kabbalat Ol Malchut Shamayim).
2. Time Remaining: If the legal time for Shema or Tefillah has not passed, one does not interrupt at all, but finishes the study session first.

This nuance establishes a key heuristic: Talmud Torah takes precedence over Tefillah only when the Kiyum (fulfillment) of the Tefillah is not jeopardized. If there is ample time remaining (b'fei kulei yoma), the continuous flow of study is preferred. This recognizes that while Tefillah is Avodat HaLev, uninterrupted Torah study is the highest form of Avodat Hashem (Torah K'Neged Kulam).

Friction

The elasticity of Tefillah creates inherent logical tension when placed within the rigid framework of Halakha. We examine two major points of friction: the contradiction regarding ZM"G in women's obligation, and the specific limitations placed on Tefillat Nedavah.

Kushya 1: The Dual Justification for Women's Obligation (ZM"G vs. Rachamim)

The S.A. 106:2 states explicitly that women are obligated in Tefillah because "it is a positive mitzvah that is not limited by time" (Shl"Z"G). This is problematic because the primary source for this obligation, Berakhot 20b, states: d'rachamei nin'hu (it is a request for mercy). These appear to be two separate and potentially contradictory justifications. If the reason is Rachamim, why rely on the Shl"Z"G classification, especially since Tefillah has fixed times (Shacharit, Mincha) that make it seem ZM"G?

Terutz 1: Tosafot and the Shl"Z"G Framework

Tosafot (Berakhot 20b s.v. d'rachamei) attempt to reconcile the seemingly contradictory reasons found in the Gemara. The Tosafot argue that while the fixed Tefillot (the Shemoneh Esrei) were instituted with fixed times, the core Mitzvah of prayer is indeed SheLo HaZman Grama.

The Chiddush of Tosafot is twofold:

1. Tefillah is fundamentally a Mitzvat Aseh to serve God with the heart, which is not confined to specific hours. This is the Rambam's view, which Tosafot accept for the nature of the obligation, even if they disagree on its D'Oraita status.
2. The reason d'rachamei nin'hu is brought not to establish the obligation, but to overrule a potential exemption. If Tefillah were only based on the fixed times instituted by the Sages, one might argue women are exempt from this D'Rabanan ZM"G structure. The Gemara teaches that because the core function of Tefillah is Rachamim—a universal human need—the exemption for ZM"G cannot apply here. The Mitzvah thus operates under the Shl"Z"G category because its necessity (Rachamim) is constant, overriding the temporal constraints of the Takkanah.[^11] The S.A. adopts this concise conclusion: the Mitzvah is treated as if it is Shl"Z"G, hence the obligation.

Terutz 2: The Ramban's Reversal of Priority (TaZ)

The Turei Zahav (TaZ) on 106:2 highlights the fact that Rashi, unlike Tosafot, simply states that the reason is Rachamim, implying that the Shl"Z"G classification is secondary or inaccurate. The TaZ, following the Ramban, argues that the Rachamim justification is primary and sufficient to enforce the obligation, even if the prayer is D'Rabanan and technically ZM"G.

This terutz views the S.A.'s formulation ("because it is a positive mitzvah that is not limited by time") not as a halakhic classification, but as a description of the Rachamim principle itself. An obligation rooted in Rachamim is inherently non-time-bound, as mercy is always required. The S.A. is thus using the term Shl"Z"G tautologically to describe a Mitzvah necessary at all times, rather than using it as a formal category that exempts women from other time-bound positive commandments.[^12] This preserves the primacy of d'rachamei while acknowledging the practical outcome cited by the Mechaber.

Kushya 2: The Prohibition of Nedavah on Shabbat/Yom Tov

OC 107:1 prohibits Tefillat Nedavah (voluntary prayer) specifically on Shabbat and Yom Tov, and for the Musaf prayer generally. If the underlying logic for allowing Nedavah is the boundless nature of Avodat HaLev (as argued by the Rosh), why restrict this elevated service precisely on days dedicated to increased sanctity and spiritual elevation?

Terutz 1: Tircha Yeteira (Excessive Burden)

The primary reason cited by Rishonim (e.g., Rashi, citing the Gemara in Sukkah 45a) for prohibiting Nedavah on Shabbat and Yom Tov is the concern of Tircha Yeteira (excessive burden).

Tefillah, especially the Amidah, requires intense concentration (Kavannah). To repeat the Amidah voluntarily requires the individual to summon this concentration a second time. On Shabbat and Yom Tov, the Halakha mandates minimizing strenuous activity and effort (Tircha) to maximize Oneg Shabbat (delight in Shabbat). The Sages viewed the effort required for a second, voluntary Amidah as unnecessary Tircha, which detracts from the physical and spiritual rest of the day.[^13]

This terutz is predicated on the idea that the spiritual benefit of Nedavah does not outweigh the violation of the Shabbat principle of ease. It is a heuristic that prioritizes the communal Takkanah of Oneg over the individual desire for increased Avodat HaShem.

Terutz 2: Kedushat HaYom and the Nature of Musaf

The prohibition is also linked to the unique Kedushat HaYom (sanctity of the day) embodied by the Musaf prayer, which is inherently restrictive.

1. Musaf: Musaf was instituted corresponding to the Karban Musaf (additional offering) brought in the Temple. Just as the Karban Musaf was fixed in quantity and time, the Tefillah is equally fixed. It is a Tefillat Chovah tied to the day’s requirement, unlike Shacharit and Mincha, which are generalized prayers of supplication instituted by the Patriarchs. The Rif and Ramban hold that because Musaf is a direct reflection of the physical Karban, it cannot be performed voluntarily, as one cannot arbitrarily offer a second Musaf sacrifice.[^14]
2. Shabbat/Yom Tov Extension: This restriction extends to the entire framework of Shabbat/YT prayers. The Tefillot on these days are defined by their reflection of the day’s unique sanctity. Allowing a voluntary repetition threatens the integrity of the fixed Chiyuv. Furthermore, since Musaf is structurally part of the day's fixed cycle, the Sages imposed a single, clear rule prohibiting all Nedavah on the Yom Tov framework to avoid confusion (Lo Plig). By forbidding Nedavah on Shabbat, the Halakha emphasizes that the primary service of the day is the fulfillment of the fixed, sacred structure, not the addition of personal, unbounded service.

Intertext

The analysis of Tefillah obligation, priority, and form in OC 106-107 connects deeply with foundational concepts across Tanakh, Talmud, and Responsa.

Parallel 1: The Metzora and the Tum'at HaGuf Barrier to Tefillah (Berakhot 21a)

The Gemara discusses the rule of Safek Tefillah (OC 107:1). A critical related discussion asks whether a person who prayed while impure (Tamei) must repeat the prayer once purified, based on the verse "and when he has purified himself, he shall pray." The Gemara rejects this reading, stating that the verse refers to the Karban (offering) of the Metzora (leper), not Tefillah.[^15]

Connection: This discussion establishes that Tefillah, unlike the Karbanot (sacrifices), is not fundamentally bound by Tum'ah (ritual impurity). The Karban is a physical act that requires Tahara (purity), paralleling the fixed nature of Musaf (OC 107:1). Tefillah, being Avodat HaLev, transcends physical impurity. This supports the structural distinction between Tefillah and Karbanot—a distinction essential for understanding why Nedavah is permitted for Tefillah (unbounded service) but prohibited for Musaf (fixed offering).

Parallel 2: The Mitzvah She'Ein La Osin Heuristic (Megillah 21a)

OC 106:3 details the rare instance where Talmud Torah overrides Tefillah (the case of RSB"Y). The underlying principle governing the interruption of Torah study for a Mitzvah is formalized in Megillah 21a and Sukkah 25a.

The rule is that one must interrupt Torah study for a Mitzvah she'ein la osin—a Mitzvah that cannot be performed by others. If the Mitzvah can be fulfilled by someone else (Mitzvah she'yeish la osin), one does not interrupt.

Connection: The Teshuvah (resolution) of the Rishonim regarding RSB"Y’s refusal to interrupt for Tefillah is complex. Some argue that because Tefillah is a constant Chiyuv (obligation) that applies to all, it might be viewed as a Mitzvah She'Yeish La Osin relative to the dedicated Torah scholar, or that the scholar's Torah study is so spiritually potent that it fulfills the world's need for Tefillah.[^16] In contrast, Kri'at Shema (which RSB"Y did interrupt for) is purely Kabbalat Ol Malchut Shamayim (acceptance of the yoke of Heaven), a personal, non-delegable declaration that cannot be compensated for by study. This distinction reinforces the idea that Shema is a singular, absolute necessity, while Tefillah is a flexible, communal service, solidifying the prioritization hierarchy in OC 106:3.

Parallel 3: The Obligation of Chinuch and Tefillin (Niddah 38a)

OC 106:2 mentions the obligation to educate children (Chinuch) in Tefillah. The general principle of Chinuch is discussed extensively in the Talmud, typically regarding Mitzvot where the child reaches the age of understanding (la'chinuch).

Connection: The Chinuch obligation for Tefillah is notable because the Tefillah itself is generally D'Rabanan (per the Ramban, the dominant view). This contrasts with Chinuch for Mitzvot D'Oraita like Tefillin. Niddah 38a discusses a child who knows how to guard their purity, thereby being obligated in Mitzvot.

The Chiddush in Tefillah Chinuch is that we educate the child in the full D'Rabanan formulation (Shacharit, Mincha, Shemoneh Esrei) even though the core D'Oraita is only a single daily request. We train the child in the Takkanah of the Sages, ensuring that by adulthood, the structure and Kavannah necessary for the full Chiyuv are ingrained. The Magen Avraham and Ba'er Hetev clarify that even under Chinuch, we must not cause the child undue suffering; thus, they are permitted to eat before Tefillah, a leniency not usually afforded to adults (Ba'er Hetev 106:2, citing M.A. 269). This shows that Chinuch prioritizes the gradual inculcation of habit over the immediate imposition of adult stringencies.

Parallel 4: The Teshuvot HaRashba on Chiddush

The requirement for Chiddush in Tefillat Nedavah (OC 107:1-2) is heavily debated in the Rishonim. The Rashba (R. Shlomo ben Aderet), in his Teshuvot, provides insight into the psychological rationale behind the Chiddush requirement.

Connection: The Rashba explains that without Chiddush, repeating the Amidah after one has already fulfilled the Chiyuv is akin to taking the Shem Shamayim (Name of Heaven) in vain, or potentially creating a berakha levatala (blessing in vain). The Chiddush serves as a heker (a marker or distinction), signaling to oneself and to Heaven that this prayer is not merely a rote repetition of the obligation but a distinct, voluntary act of Avodat HaLev. It prevents the Tefillah from becoming a mere habit, emphasizing the requirement of fresh Kavannah for every voluntary repetition.[^17] This Rashba grounds the severe requirement of OC 107:2 in the need to maintain the spiritual integrity and intentionality of the blessing structure.

Psak/Practice

The theoretical debates regarding Tefillah status and the permissibility of Nedavah have direct, significant impact on practical Halakha and meta-psak heuristics.

The Meta-Psak of Tefillah Status

The primary nafka mina of the Rambam vs. Ramban debate (D'Oraita vs. D'Rabanan) is the obligation of women (OC 106:2).

The Psak ultimately adopts the Ramban's view that fixed daily Tefillah is D'Rabanan, but agrees with the outcome of the Rambam that women are obligated. This creates a powerful meta-psak heuristic:

1. Ikar Halakha: Tefillah is D'Rabanan (Ramban, Majority of Rishonim).
2. Overriding Factor: The Rachamim principle dictates universal obligation, overriding the ZM"G exemption (Berakhot 20b).
3. Practical Reliance: Despite the Ikar Psak, the lenient minhag of women relying on the Rambam's minimum D'Oraita request persists, as documented by the Magen Avraham[^18] and Mishnah Berurah. This reliance on the D'Oraita minimum is a classic example of drawing kula (leniency) from an authoritative minority opinion when the Chiyuv (obligation) is D'Rabanan in nature.

The Mishnah Berurah strongly urges women to fulfill the full D'Rabanan obligation (Shacharit and Mincha), but acknowledges that the Minhag to omit Maariv (which was instituted as R'shut—optional—even for men, before becoming mandatory) is widespread and acceptable, as women never formally accepted the Chova status of Maariv.[^19]

The Heuristic of Safek vs. Vaday (OC 107:1)

The rule in OC 107:1—that one repeats the Amidah if in doubt (safek) whether one prayed—is a rare instance where the Halakha dictates a repetition for a Safek D'Rabanan. Typically, Safek D'Rabanan L'Kula (a doubt concerning a Rabbinic law is resolved leniently).

The exception is Tefillah. The Psak mandates repetition because the Sages were so insistent on the fulfillment of Tefillah that they treated the Safek as if it were a Safek D'Oraita, requiring stringency.

However, once one is certain of fulfillment (vaday), the Nedavah framework kicks in. The prohibition on Nedavah on Shabbat/YT and for Musaf (OC 107:1) demonstrates that while Tefillah is Avodat HaLev, its flexibility is secondary to the sanctity and fixed nature of the calendar structure. This places a limit on the individual’s desire for additional service when it conflicts with the established Takkanot of the community and the day. The Chiddush (OC 107:2) is the mechanism used to maintain the integrity of Halakha while enabling the unbounded spiritual ambition of the individual.

Takeaway

The laws governing Tefillah exemption and repetition reveal a profound tension: while Tefillah is inherently elastic and unbounded Avodat HaLev, its practical application is strictly contained by Rabbinic Takkanot concerning time, community structure, and the sanctity of the day, reflecting a balance between individual devotion and codified communal obligation.

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[^1]: Magen Avraham 106:2 s.v. Mitzvat Aseh. [^2]: Rambam, Hilkhot Tefillah 1:1. [^3]: Magen Avraham 106:2. [^4]: Ba'er Hetev 106:1. [^5]: Magen Avraham 106:2. [^6]: Ramban, Commentary on Sefer HaMitzvot, Shoresh 1. [^7]: Turei Zahav 106:2 s.v. shelo hazman garma. [^8]: Mishnah Berurah 106:4. [^9]: Rosh, Berakhot 3:3. [^10]: Rema, Orach Chayim 107:2. [^11]: Tosafot, Berakhot 20b s.v. d'rachamei. [^12]: Turei Zahav 106:2. [^13]: Rashi, Sukkah 45a s.v. d'lo b'rachamei. [^14]: Rif, Berakhot 15a; Ramban, Berakhot 21a. [^15]: Berakhot 21a. [^16]: Eruvin 13b; see Rashi and Tosafot there. [^17]: Teshuvot HaRashba, Vol. 1, Siman 182. [^18]: Magen Avraham 106:2. [^19]: Mishnah Berurah 106:4.