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Birchos Hatorah after a Daytime Nap
From The Beis Hora'ah, under HaRav Binyomin Forst
A little over a year ago, we discussed some halachos relative to one who took a daytime nap or a nighttime nap – specifically, whether or not it was necessary to wash one’s hands upon awaking and whether or not one needed to again recite Birchos Hatorah if one wished to study Torah before the ensuing morning. In this article, we will discuss in greater depth some of the halachos pertaining to Birchos Hatorah after taking a daytime nap. Classifying types of sleep is an important factor in determining the guidelines for these halachos. We will begin by reviewing the different classifications of sleep.
Types of Sleep
Halacha recognizes two classifications of sleep: shenas aray (temporary sleep) and shenas keva (regular/substantial sleep). A brief nap is classified as shenas aray. (Since the precise parameters of shenas aray are not relevant to this article, they are presented in note 2.)
A longer, more substantial sleep is classified as shenas keva. The Bi’ur Halacha records three opinions regarding the duration of sleep necessary to be classified as a shenas keva: 1) 3 hours; 2) more than 30 minutes; 3) more than 3 minutes. The consensus of the Poskim (halachic authorities) with regard to most halachos is to follow the second opinion – that a shenas keva is defined as a sleep for more than 30 minutes.
Sleeping longer than 30 minutes is classified as a shenas keva only when one sleeps in a bed or the like. If, however, one sits and lays one’s head upon one’s arms on a table and goes to sleep – even for a long time – it is classified as a shenas aray for most purposes.
Reciting Birchos Hatorah Following a Daytime Nap
The recitation of Birchos Hatorah in the morning covers all of one’s Torah study until the next morning. The Poskim discuss whether sleeping a shenas keva before the next morning ends the effectiveness of the Birchos Hatorah for the rest of that day. I.e., if one sleeps a shenas keva, and after waking up – before the next morning – wishes to study Torah, is one required to first recite Birchos Hatorah? (The discussion applies only to a shenas keva; according to all opinions, a shenas aray does not end the effectiveness of the Birchos Hatorah, and one does not recite Birchos Hatorah again before studying Torah.)
Many Poskim differentiate between a shenas keva during daytime and a shenas keva during nighttime. In this article, we will focus on a case in which one slept a shenas keva during daytime.
The Shulchan Aruch cites two opinions regarding one who slept a shenas keva during daytime as follows: “ Shenas keva during daytime is a hefsek (i.e., it ends the effectiveness of the Birchos Hatorah recited in the morning, such that upon waking from such a sleep one would be required to again recite Birchos Hatorah if one wishes to study Torah before the next morning). But some say that it is not a hefsek (i.e., shenas keva does not end the effectiveness of the Birchos Hatorah recited in the morning); and so have they customarily acted (i.e., the prevailing custom is in accordance with the second opinion, that a shenas keva does not end the effectiveness of the Birchos Hatorah recited in the morning, and that after such a nap one does not again recite Birchos Hatorah if one wishes to study Torah before the next morning).”
While a cursory glance at the Shulchan Aruch’s presentation would seem to indicate that the halacha is in accordance with the second opinion, a more focused reading would indicate otherwise. There is a general principal that when the Shulchan Aruch presents a ruling without qualification and then presents a second opinion with the introductory phrase “but some say...,” he is indicating that the halacha is in accordance with the first opinion, not the second.
Indeed, although the Shulchan Aruch records the prevailing custom as following the second opinion, the Mishnah Berurah cites numerous Poskim who rule in accordance with the first opinion, that one should again recite Birchos Hatorah before studying Torah. Accordingly, the Mishnah Berurah writes that if one wishes to recite Birchos Hatorah again, one may do so, since one has upon whom to rely. Regardless, even if one were to follow the second opinion per the prevailing custom, since the majority of Poskim rule strictly on the matter, it is proper to satisfy the first opinion in a manner such that one does not contravene the prevailing custom. To understand how to do so, some background information is necessary.
The Shulchan Aruch rules that if one recited the b’rachah of Ahavas Olam in Shacharis (see note) one fulfills the obligation of reciting Birchos Hatorah provided one studies some Torah immediately afterwards (see note). (It is appropriate to have intent when reciting the b’rachah to fulfill the obligation of reciting Birchos Hatorah, since according to some Poskim if one does not have such intent it is not effective.) The Mishnah Berurah writes that the same ruling certainly applies to the b’rachah of Ahavas Olam in Ma’ariv; i.e., if one recites Ahavas Olam in Ma’ariv and studies some Torah immediately afterwards (see note 16), one fulfills the obligation of reciting Birchos Hatorah. (Here, too, it is appropriate to have intent when reciting the b’rachah to fulfill the obligation of reciting Birchos Hatorah, since according to some Poskim if one does not have such intent it is not effective.) While, in general, we do not rely on the recitation of Ahavas Olam to satisfy the requirement of reciting Birchos Hatorah and are particular to recite Birchos Hatorah in the morning at the beginning of Shacharis, the allowance of the Shulchan Aruch and the Mishnah Berurah can be useful in cases of doubt. E.g., if one is not certain whether or not one said Birchos Hatorah, one may rely on the b’rachah of Ahavas Olam to satisfy the requirement of Birchos Hatorah provided one studies some Torah immediately afterwards.
Let us return to our case. As mentioned above, if one slept a shenas keva during the day, the prevailing custom is to follow the second opinion and to not recite Birchos Hatorah again before studying Torah that day. Nevertheless, one can satisfy the first opinion without contravening the prevailing custom by doing the following; that is, without reciting any additional b’rachos: One can have in mind when reciting the b’rachah of Ahavas Olam in Ma’ariv to satisfy the requirement of reciting Birchos Hatorah and then study some Torah immediately after finishing Ma’ariv. The Mishnah Berurah recommends that one employ this technique.,
 The Blessings of the Torah. Each morning we recite Birchos Hatorah, which is a series of b’rachos that pertain to Torah study. (There is a difference of opinion whether the series of Birchos Hatorah is considered two b’rachos or three. See Rema, Orach Chaim 47:6, Mishnah Berurah ad loc., and M.B. 46:14).
 Some Poskim (halachic authorities) rule that there is no minimum duration for a nap to be classified as a shenas aray; even napping for a few seconds would constitute a shenas aray ( Mishnah Berurah 44:4). Other Poskim rule (see ibid.) that to be classified as a shenas aray one must nap for the amount of time it takes to walk 100 amos (cubits), which is 1/67th of an hour (approximately 54 seconds); a shorter nap would not be classified halachically as sleep.
 4:16 s.v. David.
 Kitzur Shulchan Aruch 2:8; Halichos Shlomo 6:1.
 It would seem that a purposely napping recliner is considered the same as napping in a bed, especially if the footrest is being used.
 M.B. 47:23; see Ishei Yisrael chap. 6 note 64.
 Orach Chaim 47:11.
 Literally: an interruption or a cessation.
 Hebrew: v’chein nahagu.
 See Yad Malachi, K’lalei Hashulchan Aruch, #17; and M.B. 345:23. Indeed, such seems to be the Mishnah Berurah’s understanding of the Shulchan Aruch here (see M.B. 47:13).
 See M.B. 47:13.
 O.C. 47:7.
 The second b’rachah in Birchos K’rias Shema (Blessings of the Shema) of Shacharis in Minhag Sefarad and Nusach Sefard begins “ Ahavas Olam.” In Nusach Ashkenaz, the b’rachah begins “ Ahavah Rabbah.”
 The reason is that the text of the b’rachah of Ahavas Olam is similar to Birchos Hatorah ( M.B. 47:14).
 In fact, one may not study Torah immediately after reciting the b’rachah, as that would constitute an interruption in davening (praying). The Poskim write that the intent of the Shulchan Aruch is that one study Torah at the first opportunity one has to interrupt permissibly in davening, which is after Sh’moneh Esrei (before the Chazan begins chazaras hashatz – the repetition of Sh’moneh Esrei) or possibly after Tachanun (see S.A. O.C. 131:1, M.B. 131:1, and Aruch Hashulchan O.C. 131:3; see also Ishei Yisrael n.e. chap. 23 note 245). Moreover, the Poskim write that one need not be so particular, and one may fulfill the obligation by studying Torah immediately after the end of davening ( Levush O.C. 47:8, cited in M.B. 47:15; see also Ishei Yisrael n.e. 6:8, with note 25).
 See M.B. 47:13; Ishei Yisrael n.e. 6:8.
 That is, the second b’rachah in Birchos K’rias Shema of Ma’ariv.
 Preferably one should have in mind specifically when reciting the b’rachah to fulfill the requirement of Birchos Hatorah.
 [It should be noted that one can satisfy the first opinion only with regard to the Torah that one studies after one employs this technique. For the Torah that one studies after the daytime nap and before employing this technique, one does not satisfy the first opinion.]
 If one takes a nap on Shabbos afternoon and sleeps a shenas keva, there is an additional way in which to satisfy the first opinion without contravening the prevailing custom. At Minchah on Shabbos afternoon, we read from the Torah, and three men receive aliyos. The b’rachah that is recited at the beginning of each aliyah, Boruch...asher bachar banu mikol ha’amim... is the same as the most integral b’rachah of Birchos Hatorah. The napper can ask one oleh (one receiving an aliyah) before he recites that b’rachah to recite the b’rachah for the napper as well. Then, when the oleh recites the b’rachah having the napper in mind, and the napper listens to the oleh’s b’rachah having in mind to be exempted with the oleh’s recitation, it is considered as if the napper actually recited the b’rachah himself. By doing so, the napper effectively satisfies the first opinion that Birchos Hatorah must again be recited, without contravening the prevailing custom, since he did not actually recite any additional b’rachos. [This technique might actually be preferable to the first technique since he is able to satisfy the first opinion earlier in the day and need not wait until Ma’ariv to do so. Accordingly, any Torah that he studies after the aliyah and before Ma’ariv will satisfy the first opinion.]