In such cases, the presence of a minyan is both the trigger and an integral ingredient of these communal obligations. This requirement has little to do with unnecessary benedictions. Thus, without a minyan it is forbidden for anyone—man or woman—to say kaddish even though God’s name is nowhere mentioned!
The reading of Hallel or Megillat Ester, by contrast, are not mentioned in the Mishna in Megilla, since they are essentially personal obligations. One may therefore argue, as did the Sar miCoucy and Radbaz, that perhaps in these cases the presence of a minyan is not, in fact, a prerequisite.54 But when dealing with those practices and prayers mentioned in the Mishna, all authorities concur that a minyan must be there; without one, the ritual simply cannot be performed.55 Rabbeinu Tam’s patur ve-ose me-vareikh principle may allow the recitation of hovot ha-yahid, personal berakhot, but it cannot allow the recitation of devarim she-bi-kdusha nor any other hovot ha-tsibbur, communal berakhot, such as those listed in the Mishna in Megilla.
In summary, then, R. Goren’s position allowing women to perform—on a voluntary basis—a complete public prayer service, leaves much room for serious challenge. While his fundamental logic and analysis are creative and insightful, his conclusions—at least as to the extent that they apply to those public rituals and texts which constitute devarim she-bi-kdusha—appear untenable. When it comes to the latter, the Sages of the Talmud have ruled unambiguously: no act of sanctification (davar she-bi-kdusha) may take place absent of a properly constituted minyan, and, as already noted at the beginning of this paper, in the specific case of public prayer rituals, this must be a minyan of males.56
We close this section by noting that in 1989, R. Goren wrote a clarification of his 1974 responsum.57 In a lengthy letter to former Sephardic Chief Rabbi Mordechai Eliyahu, R. Goren reiterates that his 1974 correspondence was a personal one, which was publicized against his specific instructions. The original letter contained some purely speculative material, which he certainly never intended to serve as the basis of action (halakha le-ma’ase). On the contrary, it is clear that women cannot form a minyan for public prayer and, hence, cannot alone perform those rituals requiring such a quorum. In light of this retraction, there is apparently no acknowledged more hora’a—recognized halakhic authority—who condones the recitation of devarim she-bi-kdusha at women’s services.58 It is noteworthy, however, that at issue in R. Goren’s retraction is the recitation of devarim she-bi-kdusha; the late Chief Rabbi does not withdraw his fundamental support from those women’s prayer