Shiur 9: Women and Zimmun
I. Women Reciting Zimmun for themselves
The Gemara in Berakhot (45a-45b) deals explicitly with the issue of counting women towards Zimmun, the invitation to participate in the joint recitation of Birkat Ha-mazon (Grace after Meals). The discussion there starts with a disagreement whether two men who ate together are permitted to recite Zimmun. They are clearly not obligated to recite Zimmun, but there are those who maintain that they are permitted to do so if they desire. The Gemara focuses its discussion on the question of whether there exists a situation in which Zimmun is optional but not obligatory, and it attempts to decide the matter based on a beraita dealing with women:
Women by themselves invite one another, and slaves by themselves invite one another, but women, slaves and children together, even if they desire to invite one another, may not do so. (Berakhot 45b)
The beraita asserts that women may recite Zimmun in the sole presence of other women, but they may not do so in the presence of slaves. The Gemara adds another assumption: With respect to this matter, a hundred women are treated like two men. The comparison, of course, only relates to one specific point: Even a hundred women are treated like two men in that they are not obligated to recite Zimmun. If we accept the case of women reciting Zimmun for themselves as an example of an optional Zimmun, we may be able to learn from here that two men have the option of reciting Zimmun for themselves as well, even though they are not obligated to do so either.
The Gemara answers: “There it is different, as each [woman] has a mind of her own.” That is to say, indeed there exists a situation in which Zimmun is optional, but that does not mean that in every situation in which a person is exempt from Zimmun he has the option of reciting it if he desires. For when three women meet, there are three separate personalities, and therefore it is possible to offer public gratitude to God in a fitting manner. This is not the case when there are only two men. Rashi comments here that the source of this law is the verse, “Magnify [gaddelu] the Lord with me” (Tehillim 34:4). By using the plural form “gaddelu,” the verse implies that Zimmun involves one person calling out to two other people, who then answer him. This can be accomplished when there are three women, but not when there are only two men. Accordingly, three women have the option of reciting Zimmun, whereas two men are forbidden to do so.
The Tosafot understand the Gemara's discussion differently: A hundred women are like two men with respect to the fact that they are not counted towards a quorum. The Tosafot Rosh elaborates that women do not complete any quorum – not only with regard to a quorum of ten, but “for any matter that requires a quorum,” including the quorum of three that is customary for Zimmun. Nevertheless, they are permitted to recite Zimmun if they desire. From here we can derive that even two men can recite Zimmun. According to the Tosafot, the common denominator between a hundred women and two men is not that both are exempt from Zimmun, but rather that neither constitutes a group or congregation, but merely a collection of individuals.
The Gemara's answer that “there it is different, as each has a mind of her own” can be understood according to the Tosafot as follows: Though indeed women cannot be defined as a halakhic group of three, they are still three people. According to the halakha, Zimmun requires three individuals, not necessarily an official quorum of three. These three individuals may be women, but two men would certainly not fulfill the requirement.
It should be noted that up to this point the Tosafot do not argue that Zimmun for women is optional. While Rashi sees this as a fundamental aspect of the Gemara's discussion, the Tosafot understand that the Gemara does not relate to this issue at all. For this reason, the Tosafot contend with the question in actual practice. They even cite the example of “the daughters of Rabbeinu Avraham, father-in-law of Rabbeinu Yehuda,” who would “recite Zimmun based on the words of their father.” This, however, is an exceptional case, and the Tosafot discuss why it is not the customary practice for women to recite Zimmun. In the end, they conclude that Zimmun is optional for women. This conclusion, according to the Tosafot, does not stem from the Gemara, but from customary practice. Indeed, the Rosh understands the Gemara similarly, but reaches the opposite conclusion: According to him, three women are obligated to recite Zimmun, just as are three men (Rosh, Berakhot 7:4).
II. Men and Women Joining for Zimmun
The Rishonim disagree whether women can join together with men to complete the quorum required for Zimmun. Rabbeinu Yehuda Ha-kohen maintains that if two men who ate bread can join for Zimmun with a third man who ate vegetables, then certainly those two men can join for that purpose with a woman who ate bread. The Maharam of Rotenburg counters that the two cases cannot be compared. This is because, among other reasons, a man who ate vegetables can complete a quorum of ten for Zimmun (for the purpose of inserting the word “Elokeinu”), while women certainly cannot do so (Responsa Maharam Mi-Rotenburg, IV, no. 227). He also adds that a man who ate vegetables can become obligated in Zimmun by Torah law by eating bread, but a woman can never bring herself to a state of obligation by Torah law.
Rabbeinu Yehuda implies that women are obligated in Zimmun by Rabbinic decree. The Maharam does not argue with him on this point, and it may be inferred from this that he too agrees with his disciple the Rosh that three women are obligated (by Rabbinic law) to recite Zimmun for themselves. According to him, however, they cannot join together with men for Zimmun, apparently because he maintains that men are obligated by Torah law, whereas women are obligated only by Rabbinic decree.
The Maharam's position is unclear. Perhaps he means to say that women's obligation to recite Birkat Ha-mazon is only by Rabbinic decree. This is a disputed issue: The Shulchan Arukh (Orach Chayyim 186:1) writes that there is uncertainty whether women are obligated in Birkat Ha-mazon by Torah law or by Rabbinic decree. Alternatively, the Maharam’s intention may be that women's obligation in Zimmun is only by Rabbinic decree. This is certainly true, but it is not clear that regarding this point women are different from men. The Rishonim disagree whether the entire law of Zimmun is from the Torah or only by Rabbinic enactment, and it is generally accepted that men too are only obligated in Zimmun by Rabbinic enactment (Sha'ar Ha-tziyun 199, no. 19). If so, it is difficult to rely on the position of the Maharam in this matter.
Rashi proposes a different explanation as to why women cannot join together with men for Zimmun:
But two women or two slaves cannot join together with men, because men have something that women and slaves do not have, for women do not mention circumcision and slaves do not say: “For our inheritance.” (Rashi, Arakhin 3a)
Rashi notes that the text of the blessing that women recite is different from the text that men recite, and for this reason they cannot join together. Some understand the words of Rashi as pointing to a technical problem: It was customary in his day that when the Zimmun was recited, the person initiating the Zimmun would recite all the blessings of Birkat Ha-mazon out loud for the entire group. If so, there would be a problem when different individuals in the group had different texts. The Acharonim note that in our time there is less of a problem, for it is our practice that each person recites the blessings of Birkat Ha-mazon by himself, while the initiator recites out loud only the ends of the blessings.
It is possible, though, that Rashi's explanation does not stem from some technical problem, but is connected to his fundamental position regarding Zimmun. Zimmun may be understood in one of two ways: Either we are dealing with an independent blessing recited prior to Birkat Ha-mazon; or, alternatively, Zimmun is a way to pull together a group of people for a joint recitation of Birkat Ha-mazon. Rashi seems to understand that we are dealing with the second possibility, in which case the very fact that the Birkat Ha-mazon of women is different and distinct makes it impossible for men and women to join in one group by way of Zimmun. This problem may exist even if each person recites Birkat Ha-mazon for him- or herself.
Today, however, our practice is that even women say: “For Your covenant which You have sealed in our flesh; and for Your Torah which You have taught us” (see Mishna Berura 187:9). In our day, then, Rashi's argument is irrelevant to the question whether men and women can join together for Zimmun.
The Rishonim mention a third reason why women cannot join with men for Zimmun:
Rashi explains that for this reason women cannot join with men for Zimmun, even with their husbands, because their company is inappropriate. (Talmidei Rabbeinu Yona, Berakhot 33a in Alfasi)
The Gemara states that women and slaves cannot join together for Zimmun because this might lead to immoral behavior. Talmidei Rabbeinu Yona write in the name of Rashi that the same is true for ordinary men and women (this does not appear in the standard version of Rashi's commentary). They extend this restriction even to the family framework. It seems that at least there we must say that we are not referring to actual immorality. Rather, this means that men and women do not naturally mix in a respectable manner – “their company is inappropriate.”
Another variation of this rationale is mentioned by the Meiri:
Some explain that women together with free men cannot [join together for Zimmun] not because of possible immoral behavior, but because their joining has no permanence. (Meiri, Berakhot 47b)
The Meiri proposes that the problem with men and women joining together for Zimmun is not the concern that this might lead to immoral behavior, but rather that no permanent group is formed. In general, he believes, women dine separately and men dine separately; should they join together for a meal, this grouping is only temporary, and therefore does not justify Zimmun.
We see that the Rishonim disagree on this point, the majority maintaining that women cannot join together with men for Zimmun. Presumably, these Rishonim were especially inclined to rule stringently because of the contemporary practice, which is that women did not join with men. But this position is also superior with respect to the plain sense of the line in the Mishna: “Women, children and slaves are not included in Zimmun” (Berakhot 45a). Though it is possible to understand that this means that Zimmun is not recited in a group composed only of women and slaves, this does not seem to be the plain meaning of the text.
The Shulchan Arukh rules as follows:
Women, slaves and children are not included in Zimmun, but they may recite Zimmun for themselves. A group of women, slaves and children should not recite Zimmun together, because of the immoral behavior of the slaves. Rather, women [recite Zimmun] separately and slaves [recite Zimmun] separately. This is all provided that they do not use God’s name [Elokeinu]in their recitation.
Women have the option of reciting Zimmun for themselves, but when they eat together with men, they are obligated in Zimmun, and they fulfill their obligation with our Zimmun.
Rema: Even if they do not understand. (Orach Chayyim 199:6-7)
The Shulchan Arukh'sruling follows the wording of the Mishna: “Women, slaves and children are not included in Zimmun.” The Mishna Berura (no. 12) clarifies that this law refers to woman joining together with men. He explains: “Because their company is inappropriate.” And in the wake of Talmidei Rabbeinu Yona, he writes that a woman cannot join together for Zimmun even with her husband and children.
Rav Yosef Shaul Natansohn understands the Shulchan Arukh differently (Responsa Sho'el U-meishiv, version 1, III, no. 155). He rejects Rashi's argument, claiming that the concern about immoral conduct does not apply in a family setting. He argues – against the Mishna Berura – that even the Shulchan Arukh sees no problem with men and women joining together for Zimmun. According to Rav Natansohn, when the Shulchan Arukh says: “Women, slaves and children are not included in Zimmun,” he refers to a case of women and slaves joining together for Zimmun. However, Rav Natansohn does not draw any practical conclusions, and even notes that he examined the passage only superficially.
In practice, it is difficult to believe that the Shoel U-meishiv would have ruled that men and women can join together for Zimmun. As the Beit Yosef comments on the words of Rabbeinu Yehuda Ha-kohen, we have never seen or heard of a place where this is the customary practice. Nevertheless, it may be proper to encourage women to recite Zimmun for themselves, even though this is not the customary practice, since all the reasons offered as to why men and women should not join together for Zimmun do not apply in this case. Moreover, according to some views, they are not only permitted, but actually obligated to recite Zimmun for themselves.
It should be noted that even the Shulchan Arukh rules that when there are three men present, the women must participate in the Zimmun of the men and answer appropriately.
(Translated by David Strauss)
 Why is Zimmun optional for women and not obligatory? The Mishna Berura (Orach Chayyim 199, no. 16) explains: “Because the Sages did not want to obligate them in Zimmun when they are by themselves, because it is not so common for them to be proficient in the Zimmun blessing.” See Tosafot, Berakhot 45b, s.v. shani, who say that the women of his day do not understand Hebrew.
 There is room for a separate discussion whether this is indeed true, particularly with respect to reading the megilla. According to many opinions, women can be counted toward a quorum of ten people for reading the megilla, and this has halakhic ramifications. But for our purposes it suffices that, according to the Tosafot Rosh, women are not counted toward a public quorum whatsoever.
 The Bach (Orach Chayyim 199) writes that the disagreement among the Rishonim relates exclusively to women joining for the Zimmun of ten people. But the Elya Rabba rejects this position, writing that the disagreement relates specifically to the Zimmun of three. This is also evident from the wording of the responsum, which implies that all agree that women cannot join men for Zimmun of ten.
 It should be noted that the Rishonim cite an exceptional view, in the name of Rabbeinu Simcha, that women can join men even for a Zimmun of ten (Meiri, Berakhot 47b; Mordekhai, Berakhot 158; Shiltei Gibborim, Berakhot 33a in Alfasi). According to this opinion, Zimmun of ten does not fall into the category of “matters of sanctity.” Because of this, ten individuals are needed to make the recitation a public matter, and women are fit for this purpose. As stated, however, this is an exceptional position, and the Shulchan Arukh rules that when ten women recite the Zimmun, they cannot use God’s name (Orach Chayyim 199:6).
 The Peri Megadim (Mishbetzot Zahav, Orach Chayyim 199, no. 2) writes explicitly that the factors of immoral behavior and “their company is inappropriate” do not apply in a family setting. In this he contradicts the view of Talmidei Rabbeinu Yona.
 His source is apparently the Ra'avad, who writes: “As they do not have permanence” (Temim De'im, 1).