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Tam’s opinion is indeed the accepted Ashkenazic ruling,17 it is not the only view on the matter. Maimonides, R. Joseph Caro,18 and, in fact, a majority of Sephardic authorities down to the modern period—most notably R. Ovadiah Yosef,19 R. Goren’s Sephardic counterpart when the two jointly shared the position of Chief Rabbi of Israel—take strong exception to the Ashkenazic custom. These posekim strictly forbid Sephardic women from reciting berakhot when performing mitsvot from which they are exempted.20 Thus, R. Goren’s solution would not apply to Sephardic women.21

One also wonders why R. Goren insists at all on the presence of ten women. If, as R. Goren contends, Rabbeinu Tam’s principle can be applied to public prayer rituals so as to obviate the need for a properly constituted minyan, even a lone woman should be able to say any of the prayer texts without being deemed to have taken the Lord’s name improperly.21*

More fundamentally, the late Chief Rabbi interprets Rabbeinu Tam’s ruling as a special dispensation for women, based on the nahat ru’ah (spiritual satisfaction) rationale. This novel interpretation radically departs from the way in which Rabbeinu Tam’s ruling was understood by the earlier authorities. None of the rishonim22 who cite Rabbeinu Tam use the notion of nahat ru’ah as a justification for this leniency; rather, they cite explanations applicable to both genders. For example, Tosafot explain that “the blessing [of a patur ve-ose]23 Furthermore, notes R. Nissim Gerondi (Ran), the text, “. . . commanded us,” is not improper either; after all, the Talmud’s conclusion—“greater is (the reward of) one who is obligated and fulfills the commandment, than (that of) one who is not obligated and yet fulfills the commandment”24—clearly implies that the latter, too, receives at least some reward. If so, then even an eino me-tsuve ve-ose must share in the commandment. Since men are fully obligated and, as just noted, women receive reward for their actions, women may recite the berakha, the phrase “and commanded us” notwithstanding.25

As further clarified by R. Ben-Zion Meir Hai Uziel and R. Joseph B. Soloveitchik,26 the mitsvot were issued to the nation of Israel as a whole, men and women alike. Accordingly, both men and women possess an equal degree of “kedushat Yisrael,” Jewish sanctity.27 But despite sharing the general obligations of Kelal Yisrael (corporate Israel), women were granted a particular and individual exemption from the performance of time-determined commandments. This is not to say that time-determined commandments are irrelevant to women; there is a vast difference between one who is fundamentally subject to an obligation

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