Torah Study and Prayer Which Takes Precedence?
One of the most fascinating areas of Halakha relates to situations in which a competing values or mitzvot clash. There is extensive discussion both of this general phenomenon – generic guidelines such as: a positive commandment sets aside a negative commandment, the obligation to save a life sets aside the prohibitions of Shabbat, the obligation to sanctify God's name by refusing to violate certain prohibitions can supersede human life itself, uprooting a Torah law by omission is preference to commission of a transgression, and the like - and of local rules – for example: whether to give precedence to Shabbat candles or to Chanuka candles, how to decide between different types of charity, etc. All of these issues give expression to the diversity and complexity of Halakha. Recognizing that mitzvot are not all of equal value in every situation, the halakhic authorities have established hierarchies that determine which value supersedes another and which mitzva is given precedence over another.
In this article, I wish to briefly deal with one such question: If a person is engaged in Torah study, and the designated time for one of the daily prayer services arrives – which of the two values is given priority? Must he interrupt his study in order to pray, or perhaps his occupation with Torah study exempts him from the obligation to offer prayer? Is there room to distinguish between different classes of people regarding this issue? Is there a difference with respect to this question between the Shemoneh Esreh prayer and the reading of Shema? These questions, the practical answers to which are quite clear, afford us the opportunity to examine the nature of the mitzvot of Torah study and prayer, and the relationship between them.
The Mishna at the beginning of tractate Shabbat (1:2) states:
One must not sit down before a barber near Mincha until he has prayed. Nor may he enter the baths, a tannery, to eat, or a court case; yet if they began, they need not be interrupted. One must interrupt for the reading of Shema, but not for prayer.
The Gemara in Shabbat (11a) questions the redundancy in the Mishna and explains:
But the first clause already teaches: "They need not interrupt”! The second clause refers to Torah study. For it was taught: If scholars are engaged in studying, they must interrupt for the reading of Shema, but not for prayer.
That is to say, while the first part of the Mishna deals with a person's occupation with mundane activities, which le-chatkhila should not begin near the time of Mincha, but be-di'avad, if it began, it need not be interrupted – the end of the Mishna deals with Torah study, which need not be interrupted for prayer. The prevalent view among the Rishonim is that the novelty in the last clause is much greater than that of the first clause. While all agree regarding the first part of the Mishna that the allowance not to interrupt the various activities only applies when there is still time to offer the Mincha prayer, regarding the last clause, "but [one need] not [break off] for prayer" means that there is no need to interrupt Torah study, even if the time for prayer will pass and he will not pray at all! Thus writes the Ba'al ha-Ma'or (ad loc., 3b in the Alfasi pagination):
Understand that our Mishna is dealing with two different types of interruption. That which we have learned that one need not interrupt eating in order to pray – this does not mean that he may uproot [prayer] altogether, but rather where there is time to pray after eating… But the last clause which deals with Torah study, stating that scholars engaged in Torah study interrupt for the reading of Shema but not for prayer, means that one need not interrupt [Torah study] at all, and that he may uproot prayer entirely.
It must, of course, be noted that this law is limited to elite individuals, as the Gemara (ad loc.) emphasizes:
R. Yochanan said: This was taught only of such as R. Shimon b. Yochai and his companions, whose study was their profession; but we must break off both for the reading of Shema and for prayer.
Nevertheless we must understand the basis for this law, and the nature of the distinction between Torah scholars whose study is their profession and ordinary people.
III. III. One Who Is Occupied In One Mitzva Is Exempt From Other Mitzvot
It might be suggested that the allowance granted to Torah scholars is based on the principle that "one who is occupied in one mitzvot is exempt from other mitzvot" (Sukka 25a). This is the implication of the author of the mitzvot attributed to the Ran on Shabbat who asks why one must interrupt Torah study for the reading of Shema – surely one who is occupied in one mitzvot is exempt from other mitzvot! He answers: "Here it is different, for he can fulfill both of them." This answer seems to be based on two assumptions:
1) The rule that one who is occupied in one mitzvot is exempt from other mitzvot only applies when it is impossible to fulfill both mitzvot. This is the view of the Tosafot in tractate Sukka, who raise an objection against a law recorded there (26a), that those on the road are exempt from dwelling in a sukka both during the day and at night. They write as follows (25a, s.v. sheluchei mitzvot):
A question: If they can fulfill both [mitzvot}, why are they exempt? If a person has tzitzit on his garment or tefilin on his head, is he thereby exempt from the rest of the mitzvot? … Rather, certainly he is only exempt [from other mitzvot] while he is occupied in [the first mitzvot]… You must [therefore] say that here too we are dealing with a case that were they to occupy themselves with the mitzvot of sukka, they would be unable to fulfill [the other] mitzvot.
According to the Tosafot, the law that one who is occupied in one mitzvot is exempt from other mitzvot only applies when a person is actively involved in fulfilling the first mitzvot. If, however, it is possible to fulfill both mitzvot, without impairing the fulfillment of either one of them, he is obligated to fulfill both mitzvot. Thus, according to the mitzvot attributed to the Ran, the obligation to interrupt Torah study to read Shema is based on the argument that he can fulfill both mitzvot.
2) The second assumption is that regarding Torah study it is possible to talk about being able to fulfill both mitzvot. One might have argued that since it is impossible to engage in Torah study and to read Shema at one and the same time, if a person interrupts his Torah study, he cannot fulfill both mitzvot, and therefore he should be exempt from reading Shema. It seems, therefore, that according to the mitzvot attributed to the Ran, interrupting Torah study to read Shema does not impair a person's overall fulfillment of the mitzvot of Torah study; or alternatively, reading Shema is itself a special fulfillment of the mitzvot of Torah study, as will be explained below.
In any event, it is clear from this approach that, fundamentally, the rule that one who is engaged in one mitzvot is exempt from other mitzvot applies even to the mitzvot of Torah study, and that this rule constitutes the foundation for the law that one need not interrupt Torah study for prayer. According to this approach, the following question arises: why must a person for whom Torah study is not his profession interrupt his study for prayer? Surely, the principle that one who is occupied in one mitzvot is exempt from other mitzvot applies equally to all people? We must say that the law regarding Torah study is different, as Rashi writes (11a, s.v. aval anu): "But we – since we interrupt our Torah study for our professions, all the more so must we do so for prayer." That is to say, since in practice we interrupt Torah studies for mundane activities, it would be inappropriate were we not to do so for prayer.
Other Rishonim disagree with the approach of the Tosafot and the mitzvot attributed to the Ran. They maintain that the law that one who is occupied in one mitzvot is exempt from other mitzvot applies even when it is possible to fulfill both mitzvot, as long as the person is occupied with the first mitzvot. This follows from the words of Rashi on the Mishna in Sukka (ibid.), where he writes (s.v. peturim min ha-sukka) that those who were sent off on a mission to perform a mitzvot are exempt from sukka "even when they are not traveling." So explains at length the Or Zaru'a (II, no. 299), noting that if one who is occupied in a mitzvot is exempt from other mitzvot only applies when it is impossible to fulfill both mitzvot, there is no novelty in the principle:
But if he cannot fulfill both of them, why is a verse necessary to exempt him, for why should he remove himself from the mitzvot in which he is occupied and occupy himself with a different mitzvot? Even a light mitzvot is not put aside for a severe mitzvot, for man does not know the reward for mitzvot. And furthermore, one must not be like a servant who ministers to his master for the sake of receiving a reward. Rather, without a doubt, even if he is able to fulfill both of them, the Torah exempts him. This is a royal decree.
According to the Or Zaru'a, the Torah grants an absolute exemption from other mitzvot to a person who is occupied in one mitzvot, as long as he is actively engaged in that mitzvot. Even though the Or Zaru'a writes that "this is a royal decree," it seems that we can suggest an explanation – so that a person should fully occupy himself with the mitzvot before him, and not trouble his mind with other obligations. It is clear, however, that the exemption applies only as long as he is actively involved in things necessary for that mitzvot:
But only while he is actually involved in the mitzvot, e.g., he is giving a lost [animal] to eat or drink, at which time he is exempt from giving a peruta to a poor man, but at a time that he is neither feeding it nor giving it to drink, he is obligated to give him a peruta, even though the lost animal is in his house for safekeeping… But after he has wrapped himself [in his tallit] and donned tefilin, he is obligated, because that is not called being occupied in a mitzvot; and furthermore, regarding tzitzit there is no room to talk about occupation with a mitzvot, because if he so desires, he does not have to wear [the garment] at all, for the Torah does not obligate him to do so.
According to this approach, the law that "one need not interrupt for prayer" is clearly based on the law that one who is occupied in one mitzvot is exempt from other mitzvot. The Or Zaru'a's son, the Maharach Or Zaru'a (no. 183) takes this position to an extreme conclusion:
But if he began to occupy himself with a mitzvot, but did not finish, e.g., if he went to study Torah or to hear a sermon or to greet his teacher, even when he is not traveling, and even if he reached his destination and began to study, as long as he hasn't finished his study, he is exempt from all the mitzvot. This also follows from the words of my father, z"l… According to this, young men who go to study Torah are exempt from all the mitzvot as long as they are in their master's home.
The Maharach Or Zaru'a does not explain why, according to him, one must interrupt Torah study to read Shema. It might be that this stems from the uniqueness of reading Shema as a demonstration of accepting the yoke of the kingdom of heaven (see below).
IV. "And All The Things You Can Desire Are Not To Be Compared To Her"
As opposed to what has been stated thus far, the prevalent view among the Rishonim is that the rule that one who is occupied in one mitzva is exempt from other mitzvot does not apply to one who is occupied in the mitzva of Torah study. This principle is based on two sources:
1) The Gemara in Mo'ed Katan (9b) relates to a contradiction between two verses, and states:
They sat again and asked: It is written: "She [= Torah study] is more precious than rubies: and all the things you can desire are not to be compared to her" (Mishlei 3:15) – but the desires of heaven are to be compared to her. And it is written: "And all the things that may be desired are not to be compared to it" (Mishlei 8:11) – even the things that God desires are not to be compared to it! Here it refers to a mitzva that can be performed by others; there it refers to a mitzva that cannot be performed by others.
The Meiri explains (ad loc.):
Even though they said that one who is occupied in one mitzva is exempt from other mitzvot, Torah study is not included in this rule. Rather, if someone was occupied in Torah study, and a mitzva came to his hand, if that mitzva can be performed by others, he is not to interrupt [his study]… but if it can't be performed by others, e.g., nobody there but him is fit for it, or it is a mitzva cast upon his person, like lulav, shofar, honoring one's parents, burying a mitzva corpse where thee is nobody else to bury him, and the like, the [other] mitzva takes precedence and he must interrupt his Torah study in order to fulfill it, and he does not discharge his obligation through the fulfillment of the mitzva of Torah study, even if it is a light mitzva. Even though one who is occupied in a mitzva is exempt from [other] mitzvot, this was not stated regarding Torah study. Since its essence is to know how to fulfill the rest of the mitzvot, we interrupt it for any mitzva that cannot be fulfilled by others. This is the view of the greatest commentator.
According to the Meiri, the mitzva of talmud Torah is at a disadvantage when in practice it clashes with the fulfillment of other mitzvot. Since the purpose of Torah study is to know how to fulfill the rest of the mitzvot, it is therefore set aside by all mitzvot that cannot be performed by another person.
The Gemara in Mo'ed Katan seems to be quite explicit, and appears to pose serious difficulty for the position of the novellae attributed to the Ran and the Maharach Or Zaru'a, who maintain that the allowance of occupation in a mitzva applies even to the mitzva of Torah study. It is possible that these Rishonim explain the Gemara in Mo'ed Katan as did the Ritva (ad loc., s.v. kan be-mitzva):
Here it refers to a mitzva that can be performed by others – he must not put aside his Torah because of it; here it refers to a mitzva that cannot be performed by others – he is permitted to put aside his Torah and occupy himself with it. And this is the law.
According to this, we are dealing merely with permission to interrupt Torah study, but fundamentally the rule that one who is occupied in a mitzva is exempt from other mitzvot applies even to Torah study, if the person wishes to be exempt.
2) The Yerushalmi (Shabbat 1:2, 3b) says:
Doesn't R. Shimon b. Yochai agree that one must interrupt to build a sukka or to make a lulav? Doesn't R. Shimon b. Yochai maintain: One who learns in order to do, and not one who learns in order not to do, for one who learns in order not to do, it would have been better for him not to have been created? R. Yochanan said: One who learns in order not to do, it would have been better for him had the afterbirth in which he lay been turned over his face, so that he would not have emerged into the world.
According to this understanding, Torah study is set aside by other mitzvot because the essential nature of Torah study is study undertaken in order to do the mitzvot. A person who studies Torah and does not interrupt his study when a mitzva presents itself is regarded as one who studies in order not to do. This seems to leave no room for distinguishing between a mitzva that can or cannot be performed by others, but rather in all cases Torah study is set aside for the fulfillment of a mitzva. As opposed to the Meiri's explanation cited above, the reason that the rule regarding one who is occupied in a mitzva does not apply to the mitzva of Torah study does not stem from the inferiority of the mitzva of Torah study in relation to the rest of the mitzvot, but rather from the essential nature of the mitzva of Torah study.
According to this approach, we can raise a question just the opposite from the one raised against the view of the novellae attributed to the Ran: If the allowance regarding one who is occupied in a mitzva does not apply to one who is occupied in Torah study, why then does one not have to interrupt his study for prayer, as he must do for the rest of the mitzvot?
Several answers may be proposed:
1) The Meiri (Shabbat 9b, s.v., ha-Meiri ha-Mishna) writes:
The explanation: One who is occupied in the words of Torah interrupts [his study] for the reading of Shema, which is by Torah law, that is to say, the first verse, but he does not interrupt [his study] for prayer, which is by Rabbinic decree. And according to the one who says that prayer is by Torah law, the reading of Shema is nevertheless more severe, for it constitutes the acceptance of the kingdom of heaven.
The Meiri is, of course, referring to the famous disagreement between the Rambam (Sefer ha-Mitzvot, positive commandment 5; Hilkhot Tefila 1:1), who maintains that prayer is a Torah obligation, and the Ramban (strictures to Sefer ha-Mitzvot, ad loc.) and most Rishonim, who maintain that prayer is merely a Rabbinic decree, as is implied by the plain sense of several talmudic passages. The Meiri explains the difference between prayer and the reading of Shema according to the view of the Ramban, and adds that even according to the Rambam that prayer is a Torah obligation, one must interrupt one's Torah study only for the reading of Shema, which is governed by more stringent laws than prayer, owing to the fact that it constitutes an acceptance of the yoke of the kingdom of heaven.
The words of the Meiri, however, fail to answer our question: why is one not required to interrupt Torah study for prayer. Indeed, the Meiri himself writes that one must interrupt Torah study even for a lenient mitzva. It seems, therefore, that we must add that according to the Meiri there is a qualitative difference between the mitzva of Torah study and the mitzva of prayer, and that there is a special reason why the obligation to interrupt Torah study in order to fulfill a mitzva does not apply to prayer. This idea follows from the words of the Rambam himself. Even though he maintains that prayer is a Torah obligation, he writes as follows (Hilkhot Tefila 6:8):
If someone was occupied in Torah study and the time for prayer arrived, he interrupts [his study] and prays, but if Torah study was his profession, and he engages in no other work whatsoever, and he was occupied in Torah study at the time of prayer, he does not interrupt [his study], for the mitzva of Torah study is greater than the mitzva of prayer. Anybody occupied in communal affairs is regarded as if he were occupied in words of Torah.
The Rambam's explicit assertion – "for the mitzva of Torah study is greater than the mitzva of prayer" – follows from the words of the Gemara in that same passage in Shabbat (10a):
Rava saw Rav Hamnuna prolonging his prayers, and said: They forsake eternal life and occupy themselves with temporal life. But he [Rav Hamnuna] held: The times for prayer and Torah [study] are distinct from each other.
Rav Yirmiya was sitting before Rav Zeira engaged in study. As it was growing late for the service, Rav Yirmiya was making haste [to adjourn]. Thereupon Rav Zera applied to him [the verse]: "He that turns away from hearing the law, even his prayer is an abomination" (Mishlei 28:9).
The two stories imply that at least according to Rava and Rav Zeira, Torah study falls into the category of "eternal life," whereas prayer is regarded as "temporal life" – man's petition for his personal needs. For this reason, at least for those whose profession is Torah study and whose lives give expression to the highest value of Torah study, it would be inappropriate to interrupt their occupation in eternal life in order to occupy themselves with temporal life, even though they must interrupt their study for other mitzvot.
2) The Mishna Berura (sec. 106, no. 7) writes:
Even though one must interrupt his Torah study in order to perform all the mitzvot, even those of Rabbinic origin, because one who studies but does not fulfill [the mitzvot] it would have been better for him not to have been created - nevertheless, regarding prayer, since it is merely petitioning for mercy, it is more lenient than the other mitzvot for such people who do not interrupt their studies for even a minute.
According to the Mishna Berura, who relates directly to our question and mentions the Yerushalmi passage cited above, the law that Torah scholars whose profession is Torah study do not interrupt their study for prayer follows from the special lifestyle of these elite individuals. A Torah scholar's lifestyle expresses the fact that he attaches no importance to material life in this world, and therefore it is precisely a Torah scholar who should not interrupt his Torah study for prayer. The implication is that anybody else must indeed interrupt his study in order to pray, because for the rest of the world, temporal life is no small matter, and petitioning God for one's needs in this world is no less important than Torah study.
3) Rav Yosef Dov Soloveitchik understands the words of Rava that "they forsake eternal life and occupy themselves with temporal life" in a different manner. The Rambam in his Sefer ha-Mitzvot (positive commandment 5) cites the words of the Sifrei (Devarim, sec. 41):
"And to serve Him" (Devarim 11:13) – this is Torah study… Another explanation: "And to serve Him" – this is prayer.
Rav Soloveitchik writes:
A wonderful idea is contained in the words of our master, namely, that "service of the heart" relates to two things, prayer and Torah study. A person fulfills the obligation of "service of the heart" through Torah study, as he does through prayer… One who studies Torah serves the Holy One, blessed be He, with all his heart and all his soul, and he fulfills "service of the heart" as does one who engages in prayer… Thus, through Torah study it is possible to realize the fulfillment of both Torah study and prayer, and this is the reason that Rava maintains that one should not prolong prayer at the expense of Torah study.
According to this approach, we can also understand why one need not interrupt Torah study for prayer: Torah scholars whose profession is Torah study are in any event occupied in the fulfillment of the mitzva "to serve Him with all your heart," and they are not required to go change what they are doing and fulfill the very same mitzva in a different way.
V. One Need Not Interrupt Even For The Reading Of Shema
As opposed to what is stated in the Babylonian Talmud, with which we have occupied ourselves thus far, the Yerushalmi (Shabbat 1:2, 3a-b) records a unique view, according to which Torah scholars of the likes of R. Shimon b. Yochai need not interrupt their study even for the reading of Shema. The Yerushalmi presents this issue as a fundamental disagreement between R. Shimon b. Yochai and R. Yochanan:
R. Yochanan said in the name of R. Shimon b. Yochai: [People] like us, who are occupied in Torah study, need not interrupt [their study] even for the reading of Shema. R. Yochanan himself said: [People] like us, who are not occupied in Torah study, must interrupt their study even for prayer. He is consistent with his own position and he is consistent with his own position: R. Yochanan is consistent with his own position, for R. Yochanan said: Would that we would pray all day long. Why? Prayer never loses its value. R. Shimon b. Yochai is consistent with his own position, for R. Shimon b. Yochai said: Had I stood on Mount Sinai when the Torah was given to Israel I would petitioned God that two mouths be created for man, one that he might be able to study Torah and one that he might be able to take care of all his needs… R. Yudan said: R. Shimon b. Yochai, since he was sharp regarding words of Torah, therefore there was nothing more dear to him than words of Torah.
The Yerushalmi presents two understandings regarding prayer. R. Yochanan sees prayer primarily as service of God and standing before Him, and therefore he proclaims: "Would that we would pray all day long," whereas R. Shimon b. Yochai sees prayer as petitioning for man's needs, which is less important than Torah study, where man occupies himself with moral-spiritual questions rather than his personal needs, as explained above in the words of Rava. Nevertheless, the Yerushalmi raises an objection against the view of R. Shimon b. Yochai, based on his own position discussed above, that the rule regarding one who is occupied in a mitzva does not apply to the mitzva of Torah study. Why then is a person occupied in Torah study not obligated to interrupt his study in order to read Shema?
Doesn't R. Shimon b. Yochai agree that one must interrupt Torah study to build a sukka or to shake a lulav? Doesn't R. Shimon b. Yochai maintain: One who learns in order to do, and not one who learns in order not to do, for one who learns in order not to do, it would have been better for him not to have been created?…
The Yerushalmi answers:
The rationale of R. Shimon b. Yochai: This is study and this is study, and we do not set aside study for study.
There are two ways to understand the Yerushalmi's answer:
1) Talmidei Rabbenu Yona in Berakhot (9b in Alfasi, s.v. lememra) write:
That is to say, the one cannot be compared to the other, for that which involves an action is not set aside by Torah study, but a mitzva which is merely talk is set aside by Torah study.
This approach constricts the principle that one must interrupt Torah study in order to perform mitzvot, applying it only to mitzvot involving an action, to the exclusion of mitzvot that are fulfilled via speech. This explanation might be based on the Yerushalmi's wording in its question regarding "one who learns in order to do" – only mitzvot that involve an action present a problem when the person involved in Torah study fails to interrupt his study in order to do a mitzva, thus making him appear as one who learns in order not to do. Regarding mitzvot that are fulfilled through speech, on the other hand, we apply the rule that one who is occupied in one mitzva is exempt from other mitzvot, and therefore one need not interrupt Torah study in order to read Shema.
2) The simple understanding, however, is that the Yerushalmi's answer refers specifically to the reading of Shema, and that it sees the reading of Shema as a fulfillment of the mitzva of Torah study. Several proofs can be adduced in support of this understanding. First, the Gemara in Berakhot 21a records an Amoraic disagreement whether prayer is by Torah law or a Rabbinic decree:
Rav Yehuda said: If a man is in doubt whether he has recited Shema, he need not recite it again. If he is in doubt whether he has said "Emet ve-Yatziv," or not, he should say it again. What is the reason? The recitation of Shema is ordained only by the Rabbis, the saying of "Emet ve-Yatziv" is a Scriptural ordinance. Rav Yosef raised an objection: "And when you lie down, and when you rise up." Abaye said to him: That was written with reference to words of Torah.
Talmidei Rabbenu Yona (ad loc., 12 in Alfasi, s.v. amar Rav Yehuda) understand Rav Yehuda's position as follows:
Even though it says in the Torah, "when you lie down and when you rise up," he maintains that the Torah is not referring specifically to the reading of Shema, but rather that one must read from the Torah any passage that he wishes. The fact that we read this passage specifically is only by Rabbinic law.
It can, of course, be argued that according to the Yerushalmi, even R. Shimon b. Yochai maintains that the reading of Shema is only by Rabbinic decree. It is possible, however, that even if according to R. Shimon b. Yochai, the reading of Shema is by Torah law, in accordance with the prevalent view in the Babylonian Talmud and among the Rishonim, nevertheless the nature of this mitzva is a fulfillment of the mitzva of Torah study, through the reading of this specific passage, which constitutes the minimal fulfillment of Torah study each day.
Indeed, it is R. Shimon b. Yochai himself who taught the following law (Menachot 99b):
R. Yochanan said in the name of R. Shimon b. Yochai: Even if a person only read Shema in the morning and in the evening, he has fulfilled "[This book of the Torah] shall not depart [out of your mouth]" (Yehoshua 1:8).
In light of this, we can understand that according to the view of R. Shimon b. Yochai, one need not interrupt Torah study for the reading of Shema, because we are dealing with a single fulfillment. This is exactly the way that Rav Soloveitchik explains the position of the Babylonian Talmud that one need not interrupt Torah study for prayer, since they both constitute a single fulfillment.
As we saw in the preface, from a practical perspective, the issue discussed in this article is exceedingly simple, from the Gemara to the Poskim. It is clear that in our time, when nobody falls into the category of "one whose profession is Torah," a person must interrupt whatever he is doing in order to pray. Conceptually, however, we noted the importance of Torah study as an expression of the service of God, the value of which is greater than that of prayer, or parallel to it, as two expressions of a central component in our lives – the mitzva of serving God.
This article was written in honor of the dedication of the new synagogue in Alon Shevut. The community of Alon Shevut is fortunate that its synagogues are filled with the sounds of prayer and Torah, and that both of these components of the service of God are heard from afar. May it be God's will that the sound of prayer and the sound of Torah study continue to be heard, and that our prayers and Torah study be favorably accepted by God, who hears the sounds of the prayers of His nation Israel with mercy.
(Translated by David Strauss)
 The Gemara in Shabbat 9b discusses whether the prohibition mentioned here applies before mincha gedola or before mincha ketana, and the scope of the prohibited activities. The Rishonim discuss these issues at length, and a summary of the views accepted as normative law is brought in Shulchan Arukh, Orach Chayyim 232:2, Rav Yosef Karo and the Rema.
 See, for example, Tosafot to Brakhot 9b, s.v. ein mafsikin.
 So too writes the Ran (5a in Alfasi), s.v. ve-ein mafsikin, and see the proof that he brings there.
 It should be noted that Rashi implies that the novelty in the law applying to those "whose profession is Torah" is less far reaching, for he writes (11a, s.v. chaverim): "If scholars are engaged in studying, they must break off – their study for the reading of Shema, for its time is by Torah law, 'when you lie down and when you rise up,' but they do not break off for prayer." The implication is that Torah study does not totally exempt a person from the mitzva of prayer, but rather, because by Torah law prayer has no fixed time, as opposed to the reading of Shema (see below), one need not interrupt his Torah study in order to pray in its proper time. But this does not mean that he need not pray at all. This is also the implication of the Mishna Berura (sec. 106, no. 7).
 The implication is that regarding prayer, it is impossible to "fulfill both of them," apparently because of the clear difference between prayer and Torah study.
 For an explanation of this unique position, see my revered teacher, HaRav Aharon Lichtenstein, shlita, "Ha-Osek be-Torah Patur min ha-Mitzva," Kevod ha-Rav, New York, 5744, pp. 187-201.
 The Meiri writes along similar lines in Shabbat 9b, s.v. ve-shema tomar): "For study is meant merely to lead to action; how then can it cancel the action?"
 The connection between the two will be discussed below.
 HaRav Lichtenstein expands on this idea in the article cited above, note 6.
 See Kesef Mishna on the Rambam, beginning of Hilkhot Tefila, who explains that according to the Rambam, these passages mean to say that the times for prayer are by Rabbinic decree, but not that the very obligation to pray is Rabbinic in origin: "There is an obligation to pray every day, but the number of prayers is not by Torah law, one a day sufficing."
 In his article, "Birkot ha-Torah," in Shi'urim le-Zekhr Abba Mari, Jerusalem 5763, especially p. 15.
 Ibid. pp. 13-15.
 My revered teacher, HaRav Yehuda Amital, shlita, bases the obligation of women to study Torah in our day on these words of the Sifrei (Ha-Aretz Natan li-Venei Adam, Alon Shevut, 5762, p. 45). According to him, especially in our times, when the intellectual component is of such great significance in all facets of our lives, the service of God finds special expression in Torah study. Women are obligated in this aspect of Torah study, as an expression of their service of God.
 The Rishonim cite a slightly different reading of the Yerushalmi's answer. See, for example, Tosafot in Mo'ed Katan (9b, s.v. kan be-mitzva).
 See Responsa Seridei Eish, II, nos. 66, 67.
 See Shulchan Arukh, Orach Chayyim 106:2, and Mishna Berura, ibid. no. 6.