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etc., since men have no such dispensation, and as far as they are concerned, the requisite quorum is lacking.

R. Goren’s argument is unquestionably intriguing. It is, however, equally problematic. As noted above, his conclusion rests upon the view of Rabbeinu Tam and the thesis that women have a special dispensation to recite sacred texts normally requiring a minyan even when this quorum is absent. One potential challenge to this thesis is raised by R. Goren himself, and deals with the traditional introduction to the grace after meals, the “birkat ha-zimmun.” The birkat ha-zimmun must be recited when three or more adult males eat bread together. When a minyan is present, the text of the birkat ha-zimmun is amended so as to invoke God’s name by adding the word “Elokeinu,” and is then referred to as “zimmun beShem.” Although three women, too, have the option of forming a quorum for birkat ha-zimmun, Maimonides explicitly precludes ten women from zimmun beShem.14 But if R. Goren’s thesis were correct, why should ten women be precluded—why could they not say zimmun beShem on a voluntary basis, as peturot ve-osot?

R. Goren is not bothered by this seeming contradiction. He notes that the aforementioned petura ve-osa me-varekhet principle enunciated by Rabbeinu Tam is not universally accepted. Indeed, Maimonides disagrees with Rabbeinu Tam, maintaining instead that women may not pronounce benedictions which they are not halakhically bound to pronounce. Accordingly, Rambam rules—unlike Rabbeinu Tam—that women are forbidden to recite berakhot (benedictions) when performing time-dependent commandments.15 Consequently, when Maimonides proscribes ten women from reciting birkat ha-zimmun beShem, he is simply being consistent.15* Inasmuch as Ashkenazic practice has adopted Rabbeinu Tam’s view, however, R. Goren rejects any challenge to his thesis from the ruling of Rambam.

Surprisingly, R. Goren neglects to mention that even among those rishonim and aharonim who agree with Rabbeinu Tam’s ruling regarding women’s permission to recite blessings over time-dependent commandments, there is almost unanimous endorsement of Rambam’s exclusion of women from zimmun beShem.16 Apparently, then, Rabbeinu Tam’s ruling is not to be so liberally expanded as to include permission to pronounce God’s name “unnecessarily” when the “unnecessary” character results from the absence of a properly constituted minyan.

This brings us to a second problem. As R. Goren himself notes, although Rabbeinu

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