two basic forms of public worship: 1) individuals collectively praying individually, i.e., in one place at the same time; 2) individuals praying together as a community. While the latter form is by far the more preferred (and therefore required for reciting all devarim she-bi-kdusha), the former, too, has some value over private individual prayer. In addition, while “a community” for purposes of the second form requires a minyan, “in community” for the first form does not. Consequently, while a women’s prayer group may not constitute tefilla be-tsibbur of the higher order, that does not mean that “there is no fulfillment of public prayer whatsoever.” Women’s prayer groups would certainly qualify as public worship in line with the first form.122 Halakhic logic would thus compel one to conclude that for a woman, praying in a women’s prayer group is superior to praying alone in the privacy of her own home.
2. Misrepresentation of the Torah (Ziyyuf haTorah): The second claim of the RIETS Rashei Yeshiva is that women’s services misrepresent Jewish law and tradition. They note that some prayer groups aim to demonstrate that women, like men, are capable of carrying out a full public prayer service. They thereby mislead the general public into believing that women may halakhically constitute a minyan and fulfill the obligations normally limited to bona fide tefilla be-tsibbur. Based upon the writings of R. Solomon Luria (Maharshal),123 R. Schachter and his colleagues argue that such misrepresentation (ziyyuf haTorah) is biblically forbidden. Clearly, lying is generally prohibited.124 What is unique about ziyyuf haTorah is the severity of the violation, which, according to Maharshal, is grounds for martyrdom.
R. David Bleich125 concurs, though his target is the innovation of a pseudo-keriat haTorah at the women’s service. According to R. Bleich, “the use of a Torah scroll by women who candidly acknowledge that they do not thereby fulfill the rabbinic requirements [for a bona fide keriat haTorah] borders on the farcical.” Moreover, “in instituting keriat haTorah, complete with aliyyot (although without recitation of blessings), there is manifest a clear desire to establish a formal, innovative, liturgical ritual.” R. Bleich bases his objection on Maimonides’ ruling126 forbidding non-Jews to develop religious practices of their own. As R. Bleich explains, the reason for this prohibition is that such an innovative “practice acquires the characteristics and overtones of a divinely mandated ritual and as such itself becomes ziyyuf haTorah—a falsification of the mesora (divine tradition).” This prohibition binds Jews as well, and in his view, the women’s service Torah reading, as presently