Prayer II: Shemoneh Esrei
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Daily Shemoneh Esrei
As we have seen here, the Mishna states clearly that women are obligated in prayer. The Talmud explains that when we pray, we seek God’s mercy – which all people need. Therefore, even if prayer is considered a positive time-bound mitzva, it is not one from which women are exempt.
SHEMONEH ESREI In rabbinic literature, the term 'tefilla' typically means Shemoneh Esrei. It follows that when the Mishna and Talmud stipulate that women are obligated in prayer, they are most likely referring to the obligation to recite Shemoneh Esrei, a fixed and formulated prayer.
Indeed, this is how Mishna Berura explains the position of Ramban and "most halachic authorities."
Mishna Berura 106:4
The opinion of Ramban is that the primary mitzva of prayer is from the rabbis, the Men of the Great Assembly, who enacted a sequence of shemoneh esrei berachot (eighteen blessings), to recite morning and afternoon [as a matter of] obligation, and [in the] evening as non-obligatory. Even though it is a positive time-bound rabbinic commandment and women are exempt from all positive time-bound commandments…even so they obligated them in shacharit and mincha like men, since prayer is seeking mercy. This is the primary [halacha], since this is the view of most of the halachic authorities.
According to this view, women are fully obligated to recite shemoneh esrei at least twice every day, "morning and afternoon," shacharit and mincha. Once there is an obligation in prayer, the full set of laws apply.
Based on this school of thought, the time limits set for each of the prayers also apply to women. Women and men should endeavor to recite the morning Shemoneh Esrei by the end of the fourth halachic hour (zeman tefilla), or, failing that, by chatzot, halachic midday, and should complete the afternoon Shemoneh Esrei by sheki'a, halachic sunset.
MA'ARIV Must women recite ma'ariv? When Mishna Berura describes a woman's obligation in Shemoneh Esrei, he mentions only shacharit and mincha. He goes on to explain why:
Mishna Berura 106:4
All this is with regard to shacharit and mincha. Ma’ariv, however, is non-obligatory; and even though now all of Israel have accepted it upon themselves as an obligation, in any case women did not accept it upon themselves and most of them do not pray ma'ariv.
Ma'ariv was originally non-obligatory even for men, and only later took on the status of a binding custom. (See more here.) Mishna Berura reasons that while men accepted upon themselves the binding custom to recite ma'ariv, women as a whole never did, and therefore are exempt from reciting it.
His contemporary, Aruch Ha-shulchan, disagrees. He finds it difficult to justify a woman's not reciting three tefillot every day if women are obligated in the rabbinic mitzva of daily prayer.
Aruch Ha-shulchan OC 106:7
With difficulty one can explain why our women are not careful in all three prayers according to the view of Rashi and Tosafot [that the obligation of daily tefilla, in which women are obligated, is rabbinic].
Once women are obligated to recite Shemoneh Esrei, that obligation should extend to all of its daily recitations. Aruch Ha-shulchan gives no indication that ma'ariv should be treated any differently from other prayers.
There is long precedent for ruling that women must recite ma'ariv. Ramban's contemporary in Catalonia, Rabbeinu Yona, instructs women to pray three times a day.
Derashat Ha-nashim of Rabbeinu Yona
A woman should be careful to pray evening, morning and afternoon.
In seventeenth-century Ashkenaz, the Council of the Four Lands, the governing body of the Jews of Poland, issued a proclamation about a new siddur. They began with a statement that all Jews, women included, should pray three times a day:
Proclamation of the Council of the Four Lands, 1617
It is known and made public in Torah, Nevi'im and Ketuvim and more explicit in the words of our sages the great value of prayer, which is called the service of the heart. It is an obligation on every Jewish person, man and woman, young and old, to pray three times a day, evening, morning, and afternoon, which are the prayers shacharit, mincha, and ma'ariv.
There is no indication here that women should, or did, pray any less than men.
IN PRACTICE Many halachic authorities follow the view of Mishna Berura and do not require women to recite ma'ariv. It is, however, praiseworthy to do so, and if a woman misses her regular mincha, she should recite it. Some authorities, such as Rav Ben Tziyon Abba Sha'ul (twentieth-century Yerushalayim), recommend that an individual woman who chooses to recite ma'ariv should stipulate that she does not intend to obligate herself in it, lest it become a binding custom for her.
Or LeTziyon 2:7 Laws of Prayer s.v. U-mikol
In any case, women are not obligated in ma’ariv, since the basic halacha is that the evening prayer is non-obligatory…and in any case it is good for a woman to pray three [daily] prayers like men, and it is good for her to say that she does not accept the evening prayer upon herself as an obligation.
CONSENSUS? From the texts we have seen, it seems that women should recite Shemoneh Esrei of at least shacharit and mincha daily, and preferably also of ma'ariv.
However, there is a widespread practice for women to pray less often, and sometimes without a set text. Let's explore different possible halachic justifications for this practice.
Rambam's position regarding women's obligation to pray is ambiguous in a way that can provide grounds for a more lenient approach to women's prayer.
Rambam differentiates between the Torah-level and rabbinic-level obligation to pray. He defines the Torah-level obligation as a daily personal expression of praise, supplication, and thanks, and in the context of discussing it, he writes that women "are obligated in prayer since it is a positive commandment that is not time bound.”
Rambam, Laws of Prayer 1:2
Therefore women and slaves [who are also exempted from positive time-bound mitzvot] are obligated in prayer because it is a positive commandment that is not time-bound. Rather the obligation of this mitzva is thus: that a person beseech and pray every day and relate the praise of the Holy One, Blessed be He, and after that request his needs that he requires through request and pleading and after that he gives praise and thanks to God for the good that he has bestowed on him, each person according to his capability.
Rambam does not explicitly write here that women are obligated in the rabbinic framework of prayers, which uses the set language of Shemoneh Esrei and requires recitation at set times.
Later on, however, after discussing rabbinic laws of prayer, Rambam writes again that women are obligated:
Rambam, Laws of Prayer 6:10
Women…are obligated in prayer.
Rav Moshe ben Chaviv (seventeenth-century Eretz Yisrael, Sefardi Chief Rabbi) points out the gap in Rambam and how this statement may address it:
Kapot Temarim Sukkah 38b
Nevertheless, I have an uncertainty about Rambam. Why did he [Rambam] not write that women are obligated in three [daily] prayers? Perhaps he relied on what that he wrote at the end of Chapter Six of the Laws of Prayer, “women and slaves are obligated in prayer...” The simple reading of his words there appears to be that the obligation under discussion is [that of] the three [daily] prayers and that is because they are seeking mercy, and note it well.
Given that Rambam discusses women's tefilla also in the context of the rabbinic obligation in prayer, it is fully plausible that he obligates women in the rabbinic obligation of three daily tefillot. Once the Torah-level obligation applies to women, why shouldn't the rabbinic obligation also apply?
In his commentary to Shulchan Aruch, Magen Avraham suggests another possible reading of Rambam. He claims that Rambam might think women are not obligated by the rabbinic requirements of prayer, and that this is the basis for the practice of many women not to utter formal prayers, but to recite a daily, informal prayer to God:
Magen Avraham OC 106:2
So writes Rambam, who maintains that prayer is a positive Torah-level mitzva, as it is written, "to serve Him with your heart." But from the Torah it is sufficient once a day and in any language that he desires and therefore the practice of most women is not to pray regularly, because they immediately say in the morning right after hand-washing some supplication, and from the Torah this is enough. And it is possible that even the sages did not obligate them in more. But the Ramban maintains that prayer is rabbinic and thus is the view of most of the halachic decisors.
According to Magen Avraham, Rambam could read the Mishna and Talmud as obligating women only in the Torah-level obligation to pray. A daily unscripted "supplication" would suffice for that.
Magen Avraham uses uncertain phrasing: "It is possible that even the sages did not obligate them [women] in more." He does not explain how a "supplication" alone could satisfy the requirement to utter daily praise, request, and thanks, nor does he explain Rambam's statement of obligation in Hilchot Tefilla 6:10.
For these reasons, especially coupled with his pointing out that "the practice of most women is not to pray regularly," it appears that he is writing a limmud zechut, less a clear halachic argument than a defense of common practice.
Still, luminaries such as Rav Ovadya Yosef do rule that a woman, Sefardi or Ashkenazi, may rely on Magen Avraham's lenient interpretation of Rambam.
However, as we have seen, Rambam maintains that the set language of Shemoneh Esrei was instituted to ensure that individual prayer will adequately articulate of all a person's needs. It follows that, even according to those who obligate women in only one tefilla a day, the best way to fulfill this obligation is through recitation of Shemoneh Esrei.
Yechaveh Da'at 3:7
Women are obligated in one prayer a day…they should pray Shemoneh Esrei. If they were busy and preoccupied until the time of shacharit passed, they should pray Shemoneh Esrei at mincha. If women want to pray three prayers each day, a blessing should come upon them [for doing so]. Thus it is fitting for them to conduct themselves [reciting Shemoneh Esrei thrice daily] whenever they have availability to do so…
Rav Yosef maintains that women praying once a day "should pray Shemoneh Esrei."
● How can there be so much divergence between the halachic texts and common custom? (See Appendix One.)
Is there any other basis for women to pray less than two daily Shemoneh Esrei prayers, at shacharit and mincha?
Occupation with child-rearing or another mitzva may provide additional justification for women who omit prayers. While Mishna Berura rules that women are obligated in Shemoneh Esrei of shacharit and mincha, his son reports that he told his wife that caring for children released her from her prayer obligations.
Sichot Chafetz Chayyim 1:27
My mother of blessed memory almost did not pray the entire time that we remained under her supervision. For she said to me that my father exempted her from this because she was busy with raising her children.
Why should being "busy with raising her children" affect the practical obligation to pray? We find two main approaches to explaining why women may sometimes have permission not to recite Shemoneh Esrei.
I. INTENTIONALITY As we learn from Chana, prayer demands intentionality (kavana). A Talmudic passage suggests that one should not pray at all if unable to concentrate
Rav Chiyya bar Ashi said in the name of Rav: One whose mind is not settled should not pray.
Can this idea release mothers with young children in their care from praying when childcare makes concentration impossible? Chazon Ish reportedly said that it could:
Responsa Machazeh Eliyahu 19
I heard in the name of the Chazon Ish that when he was asked regarding the obligation of women in prayer, he responded that women who care for children are included among those about whom it is explained in Eruvin that "one whose mind is not settled should not pray." So too, [for] women whose minds are unsettled, there is great room to be lenient and allow them to discharge [their prayer obligation] with a short prayer…for even without this, there is the opinion of Magen Avraham that one can le-lamed zechut [view women who do not recite Shemoneh Esrei meritoriously]…
Chazon Ish applies the principle of "one whose mind is not settled should not pray" to women caring for children. Especially in conjunction with the Magen Avraham’s lenient reading of Rambam, this can serve as justification for women who do not pray.
Unfortunately, however, most of us rarely manage to focus properly on prayer even under optimal conditions. Shulchan Aruch writes that this affects the requirement to concentrate:
Shulchan Arukh OC Laws of Prayer 98:2
Now we are not careful about all this, because we do not focus so much [successfully] in prayer.
Although there may be leniency when a person cannot think about the words at all, halacha generally dictates that we have to pray even if we are distracted or preoccupied.
● Is it worthwhile to pray even without much intentionality? (See Appendix Two.)
BEING OCCUPIED WITH A MITZVA An alternative justification is based on a Talmudic principle that involvement in one mitzva releases a person from another.
One who is occupied with a mitzva is exempt from [another] mitzva.
A person actively engaged in performing one mitzva should not simply drop that mitzva when another one comes his or her way. If it is possible to perform both without difficulty, both should be performed.
Does this apply to parents who are busy raising children?
A number of modern halachic authorities cite this principle as a basis for women’s exemption from prayer, including Rav Abba Shaul.
Or Le-Tziyon 2:7:24
In any case a woman who is caring for children and is busy with that all day and does not have free time in the course of the day to pray, is fully exempt from prayer, for behold she is like one occupied with a mitzva who is exempt from [another] mitzva…and this is [also] the law for a man, that if the wife is not at home, e.g., she has gone to give birth, and the husband needs to care for the children and does not find time to pray, that he is exempt from prayer because he is occupied with a mitzva…
While other authorities bring this consideration only alongside the Magen Avraham’s lenient reading of Rambam, which applies exclusively to women, Rav Abba Shaul extends the argument to men caring for their children. However, it is clear from the example he brings—when the mother is giving birth—that he does not imagine men would apply this halacha as widely as women do. Presumably, this reflects not only a sociological assumption that mothers are the primary caregivers, but also a halachic consideration that men cannot rely on the lenient reading of Rambam.
Perhaps because the halachic exemption of being occupied with a mitzva applies specifically when one is actively engaged in performing it, Rav Abba Shaul specifies that this applies when a woman "is busy with that [child-care] all day and does not have free time in the course of the day to pray."
CAVEAT Someone relying on leniency or limmud zechut associated with child care or another mitzva should attempt to pray more fully when that is not on her shoulders. On the whole, Rav Moshe Sternbuch cautions against over-reliance on these leniencies.
Responsa Teshuvot Ve-hanhagot I:74
Indeed it appears that the obligation is in accordance with her ability…but if possible, she should pray shacharit, mincha and ma'ariv daily, in accordance with the view that women are obligated in all the prayers like men. So too, prayer connects a person to his Creator, and therefore she should make an effort to pray according to her capability, as I wrote.
Rav Sternbuch does not question the legitimacy of a woman praying less often, but he fears that when a woman does this, she may risk losing the special communion with the Creator that prayer provides. "Prayer connects a person" with God. To protect that connection, each woman "should make an effort to pray according to her capability." It is up to every woman to determine for herself what her capability is at each stage of her life.
● Once there is limmud zechut, should a woman rely on it? (See Appendix Three.)
Appendix One: How can there be so much divergence between the halachic texts and common custom?
Halachic texts teach that women should pray Shemoneh Esrei at least twice a day, especially when child-rearing or other mitzvot do not interfere. And yet there is also a consensus that the custom of many women is to rely on limmud zechut to pray less—either only one Shemoneh Esrei a day or even a shorter personal prayer. How can that be?
Halacha is an interplay between textual tradition and custom. Some of us grew up with mothers who were careful to recite Shemoneh Esrei on a regular basis. Others grew up with mothers who were scrupulous in their religious observance, but did not open the prayerbook much. Some of these women might have lacked the literacy needed to open the books, or may have learned to pray from mothers who did not read Hebrew.
Women who have the ability to satisfy the simple meaning of the Mishna and Talmud and recite Shemoneh Esrei should absolutely do so. But many women who are committed to Torah observance also find other paths to prayer, especially if they are raising young children, and halachic authorities recognize this and seek to defend it. At heart, prayer is an audience with God. Jewish women have always engaged in prayer, whether through a running conversation with God or though recitation of Tehillim or techinot, personal prayers. Sometimes prayer can be an experience that is less formal and more naturally intertwined with daily life, and this lived form of prayer is also deeply meaningful and valuable, even though it has not been formalized.
Appendix Two: Is it worthwhile to pray even without much intentionality?
Formal prayer, even if it lacks optimal intentionality, is still service of God and still praiseworthy. Ideally, we focus on the meaning of each word as we say it. Practically, so long as a person concentrates on the words of the first blessing of Shemoneh Esrei and otherwise has in mind in general that prayer is standing before God, that is enough.
Rabbi Nachman of Breslov offers a teaching that can be helpful to those of us who struggle on a regular basis to concentrate.
Likkutei Moharan 65
For each and every utterance is a full world, and when a person stands to pray and says words of tefilla, then he gathers blossoms and flowers and pretty lilies. Like a person who walks in a field, and gathers lilies and beautiful flowers one at a time, until he makes one bouquet.
One can think of prayer like moving through the garden, gathering each letter like a beautiful flower, gradually accumulating words and sentences. We may not succeed in focusing on each and every moment, but we hold onto those we can and as we progress through the garden, we attain a wholeness of experience, a bouquet of the soul.
Different stages of life allow for different types of focus on prayer. For example, a woman without heavy responsibilities may find that she has the time and perspective for deeper prayer. A woman with many responsibilities may pray only very quickly, and struggle to do that. As we move through life, our experience of prayer can change, especially if we continue to make an effort.
Appendix Three: Once there is limmud zechut, should a woman rely on it?
Between Magen Avraham's explanation of Rambam, later authorities' lenient rulings, especially for mothers, and the tendency of women who do pray not to do so in a public setting most weekdays, it can be hard to get a handle on a woman's obligation to pray.
Anecdotally, there are religiously committed women who never miss a Shemoneh Esrei and others who hardly ever recite it, all of whom can adduce halachic support for what they do.
The most important thing may be, as Rav Sternbuch suggests, for a woman to understand what is at stake, and to make sure that she is maintaining a constant connection to God, even if it is less based on formal prayer.
Rachel Weinstein, translator for Deracheha, writes in a similar vein:
Rachel Weinstein, "Biktana," Ashira.co.il
A few years ago, I discovered that there is halachic permission for a woman busy with raising her children not to pray. This did not jibe with the education I received at home and at school. But beyond the contradiction and the halachic debate, I wanted to contact the rabbis who permit it and ask them, in tears, "So, I don't have to pray? Now what? How will I bring God into my daily life?" …If for years we don't speak with Him, it is hard to reconnect. But if every day we [at least] send Him our regards, speak to Him even a bit, on a small scale, even if it's without a lot of concentration, then when one day we have the free time to really pray—the channel is open. There's a connection.
If a woman can make time to pray, that is wonderful. When children are involved, they can learn as they grow from watching her pray that she, too, has a spiritual life and commitments that they must learn to respect. Even a woman who does not pray formally on a regular basis should, at minimum, take care to check in with God.
Child-rearing itself is avodat Hashem, as are other mitzva-related obligations, and we should not forget that. A woman who prays less because of family responsibilities can focus on how those responsibilities themselves are the way in which she is serving Hashem at that time. Every woman is different and different life circumstances can call for different responses.
We can encourage women to pursue prayer and to view it as a powerful tool that enables us to connect to our Creator, while at the same time respecting each individual woman's ability to assess what will work for her at any given stage of life.
A woman who is not able to pray Shemoneh Esrei because of other mitzva obligations should still appreciate the value of establishing a relationship with God through prayer, and remains obligated to connect to Him daily through personal expressions that include praise, request and thanks.
 The length of a halachic hour varies proportionately with daylight. The times for a given location can be found on zemanim charts, websites, and apps. Laws of timing of Shema and birchot keri'at Shema are not the same as the laws of timing of Shemoneh Esrei. It is less easy to permit reciting them later. We discuss this further in a forthcoming piece.
 Magen Avraham, however, suggests women did accept ma'ariv, just not on Saturday night.
Magen Avraham 299:16
Even though they [women] are obligated in prayer, in any case, most of them were not accustomed to praying on Saturday nights. One might say that this is because ma'ariv is reshut [not fully obligatory] but that they [men] took it upon themselves as an obligation and women did not take it upon themselves on Saturday night.
 Yisrael Halperin ed., Pinkas Va’ad Arba Aratzot 341-525, Expanded Second Edition (Jerusalem: Mossad Bialik, 1945) 31, Siman 92.
 See also Responsa Benei Banim II:19, available here:
 Parallel arguments can be found in Machazeh Eliyahu 19, available here:
and Bnei Banim II:6, available here:
 As noted in note 3, Magen Avraham himself suggests that many women recited ma'ariv regularly, and writes that women are "obligated in prayer." This is further support for viewing his words here as a limmud zechut.
 Tosafot Sukka 25a s.v. sheluchei mitzva
It is astonishing if they can fulfill both, why should they be exempt? Should a person with tzitzit on his garment and tefillin on his head be exempt by dint of that from other mitzvot?...Rather it certainly only exempts him at the time when he is [actively] occupied with it [the mitzva].
 Ran on Rif Sukka 11a
We learn that anyone who is [actively] occupied with service of God, the Torah did not obligate him to exert himself and fulfill other mitzvot even though it is possible. Nevertheless I concede that certainly anyone who does not need to exert himself at all but, while normally performing the first mitzva, can discharge both of them – in that case he should certainly discharge both of them….
 See also:
Teshuvot Ve-hanhagot I:74
According to our words, aside from the exemption as someone occupied with a mitzva and as caretakers to the sick, she [a woman] is also exempt because she is like someone subject to outside circumstances beyond her control.
Responsa Divrei Yatziv I:121
There is great room to say that women that have little children and are responsible for their care were concerned that due to their prayer they would be unable to care for them properly, and are like someone who is occupied with one mitzva and thus exempt from another mitzva.
Az Nidberu 11:48
For the custom that [women] do not pray is because they are busy with children and one who is occupied with a mitzva is exempt from [another] mitzva…
 Rachel Weinstein, “Biktana,” Ashira. 18.5.2016, http://ashira.co.il/27702.html