Thus, Rabbeinu Tam’s heter (permissive ruling) to allow reciting a benediction over the voluntary performance of a commandment is broad in that it applies to both men and women alike. At the same time, however, it is apparently narrow in that it does not apply to those cases where the lack of obligation stems from the absence of a required minyan.
Further investigation, however, demonstrates that the matter is not so simple. While the above analysis indeed reflects the view of the vast majority of scholars, argumentation similar to that of R. Goren has been posited by isolated halakhic authorities in permitting to the individual certain religious practices which are normally communal. The first instance is the custom of reading Hallel on Rosh Hodesh with its attendant blessings. According to many geonim and rishonim, since the recitation of this particular Hallel is a custom, its benedictions can be said only together with a minyan.37 Rabbeinu Tam dissents, however, allowing individuals to recite the Rosh Hodesh Hallel with its berakhot, even in the absence of a minyan—its minhag character notwithstanding.38 Yet a third position is held by the 13th century French Tosafist, R. Samson ben Samson of Coucy (called “HaSar miCoucy”). Invoking the patur ve-ose me-vareikh principle, he argues39 that even if a minyan is required to recite the Rosh Hodesh Hallel with its berakhot, an individual can do so voluntarily, “similar to lulav and tefillin,”40 where women make blessings even though they are not obligated.41
The second case concerns the reading of the Book (or Megilla) of Esther. While the Megilla is generally read on the fourteenth of Adar and on the fifteenth in walled cities, there are circumstances where the Megilla is read as early as the eleventh day of the month.42 Although some difference of opinion exists on the matter, the general halakhic consensus is that the presence of a minyan is only preferable—but not an absolute requirement—when the Megilla is read on its designated date, i.e., on the fourteenth of Adar generally, and on the fifteenth in walled cities.43 But when the Megilla is read at any other time (she-lo bi-zmano), the presence of a minyan becomes a prerequisite for the reading and its attendant blessings (three before and one after).44 Whenever a minyan is required but unavailable, one is perforce freed from the obligation of reading Megillat Ester. Nevertheless, applying Rabbeinu Tam’s patur ve-ose me-vareikh principle, R. David Ibn Zimra (Radbaz)45 and R. Israel Jacob Algazi46 argue that an individual should still have the option to read the Megilla with its attendant berakhot, despite the absence of a minyan.
These two examples seem to indicate that a few authorities maintain that Rabbeinu