Insights into Halacha

For the week ending 10 February 2024 / 1 Adar Alef 5784

More Common Kiddush Questions:

by Rabbi Yehuda Spitz
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Kiddush B’Makom Seudah

Have you ever wondered why after partaking of Kiddush in shul, many people nonetheless make Kiddush again at the onset of their Shabbos Day Seudah? If one already fulfilled their Kiddush obligation in shul, what would the requirement possibly be for another at home? How many times must Kiddush be recited? Additionally, if people generally make Kiddush on Mezonos on Shabbos Day, why don’t we do that Friday night as well? Interestingly, the answers to all of these questions are intertwined. But to gain a proper understanding of the relevant issues, some background is order.

Mattan Torah, the most pivotal event in Jewish history, is prominently featured in ParashasYisro and the end ofParashas Mishpatim. The fourth of the Aseres Hadibros is the exhortation to remember and keep the Shabbos properly. In fact, the Gemara teaches us that ‘Zachor es Yom HaShabbos lekadsho[1] is not only the basis of our obligation to make Kiddush upon Shabbos’s entrance on Friday night, but also a support for making Kiddush on Shabbos day.[2]

There are differences, however. Friday night’s Kiddush, marking the beginning of Shabbos, is an actual chiyuv Deoraysa (Biblical obligation), based on the aforementioned pasuk.[3] Yet, Shabbos Day’s Kiddush is purely a rabbinic enactment to honor the Shabbos. As the Rashbam, citing the Sheiltos D’Rav Achai Gaon, explains, the reason why we make Kiddush on Shabbos day is in order to show honor to the day, by drinking wine, which highlights the difference between weekday and Shabbos.[4] One practical difference between the two is that the preamble to Friday night Kiddush (Vayechulu) is actually part of the Kiddush, attesting to Hashem’s creation of the world in six days, as opposed to Shabbos Day, when the sum total of the Kiddush is actually just the bracha of ‘Hagafen.[5]

Defining Delight

Yet, there is another integral component to Kiddush besides the Kiddush itself. The Gemara Pesachim, citing Shmuel, and duly codified as halachah,[6] rules that Kiddush must be performed B’makom Seudah, in the same place as a meal. In other words, in order to fulfill the Kiddush obligation, it must serve as the preamble to an actual Seudah.

The Rashbam explains that this halachah is gleaned from the pasuk in Yeshaya,V’karasa L’Shabbos Oneg, and you will proclaim Shabbos as a delight for you,’ meaning in the same place where you proclaim Shabbos (making Kiddush), there must also be the delight (referring to celebrating the Shabbos Seudah).[7]

But now that we know that Kiddush must always come before a Seudah, what exactly must this Seudah consist of? How do we define this ‘delight’? Here is where it gets complicated.

Both Tosafos and the Rosh explicitly state that this Seudah must be an actual bread meal,[8] meaning the full Shabbos repast replete with washing,[9] Mayim Acharonim,[10] and Bentching. However, the Tur cites an opinion of the Gaonim that for this halachah, Seudah does not necessarily mean a full Seudah, but rather eating only a bit (‘achal davar mu’at’) or even drinking a cup of wine is sufficient.

The Beis Yosef[11] opines that Tosafos and the Rosh did not mean to actually disagree with the Gaonim, but rather would concur that a full meal is not actually mandated. Accordingly, their intent was to state that in order to constitute a meal, a small amount of bread would suffice; but not precluding that drinking a cup of wine would as well. Although many question the Beis Yosef’s supposition of Tosafos and the Rosh’s opinions,[12] nevertheless, in his Shulchan Aruch, the Beis Yosef codifies this as actual halachah, that one may fulfill his obligation of Kiddush B’makom Seudah utilizing (an additional cup of) wine as his Seudah.[13]

Munching Mezonos

The Magen Avraham takes this ruling a step further.[14] He explains that if a Seudah for Kiddush purposes includes wine, whose bracha is Hagafen,[15] then certainly it would include ‘minei targima,’ types of cakes and cookies (of the five grains), whose bracha is Mezonos. This is because in the order of preference of brachos (hamega’eish),[16] Mezonos is considered more important that Hagafen. If so, certainly one may consider noshing on Mezonos as a Seudah for Kiddush purposes.

This novel approachof the Magen Avraham’s was accepted and considered ‘Minhag Yisrael’ by all sectors of world Jewry.[17] That is why by almost any Kiddush in almost any shul anywhere in the world it is de rigeur to have a Kiddush with minei Mezonos as the Seudah.

Kiddush Controversy

However, not every authority agreed with the Magen Avraham’s view. For example, Rabbi Akiva Eiger and the Tosefes Shabbos argue that wine should not fit in the Seudah category (this approach would technically also invalidate using Mezonos, as its use is gleaned from wine’s “Seudah-ability”). Moreover, the Vilna Gaon famously did not rely on this leniency at all, and made certain that his Kiddush (even on Shabbos day) was exclusively ‘B’makom Seudah Gemurah’, meaning, a full bread Shabbos Seudah, ‘from soup to nuts’.[18] Although here the Vilna Gaon’s shittah is considered a minority opinion, nevertheless, the Pri Megadim, Mishnah Berurah, and Aruch Hashulchan all considered it preferential to be particular to perform Kiddush along with a full Seudah.[19] Based on this, as well as the opinions of many Rishonim, there are those who are makpid not to make Kiddush unless as part and parcel of a full bread-based Seudah.[20]

Night or Day?

Although the Magen Avraham did not distinguish between the Friday Night and Shabbos Day Kiddush, and held that his ruling should apply equally, on the other hand, Rav Yitzchok Elchanan Spektor, the Kovno Rav and Gadol Hador of the late 1800s, did. He explained that on Shabbos Day, when Kiddush is only mandated derabbanan, one may certainly rely on Mezonos as a Seudah. Yet, on Friday night, when Kiddush is an actual chiyuv deoraysa, due to the strength of the opposition to the Magen Avraham’s approach, he maintains that one should not rely on mere Mezonos, but should ensure that Kiddush is recited along with an entire bread-based Seudah.[21]

This is why one does not often see a Friday night Kiddush being performed with Mezonos instead of Hamotzi.[22] An interesting upshot of this shittah is that many Yeshivos, following the Chazon Ish’s precedent based on this approach,[23] do make Kiddush on Simchas Torah night on Mezonos, as the Kiddush on Yom Tov, even at night, is also derabbanan.

Kiddush X 2

This also explains why many are makpid to make Kiddush again as part of their Shabbos Day Seudah at home, even after partaking of Kiddush in shul. As Rav Yosef Chaim Sonnenfeld, and later Rav Moshe Sternbuch pointed out,[24] although according to the normative halachah, Kiddush-goers had already fulfilled their obligation in shul, nevertheless, according to the Vilna Gaon, they have not done so at all. Therefore, they assert, in order to ascertain that one be yotzei Kiddush B’makom Seudah according to all opinions, one should make Kiddush again as part of the actual Seudah.

Rav Shlomo Zalman Auerbach,[25] the Minchas Yitzchak,[26] the Betzeil Hachochma,[27] and Rav Yosef Dov (JB) Soloveitchik,[28] also maintained preference to recite Kiddush again as part of the actual Seudah.[29]

Rav Moshe Feinstein[30] takes a different, and admittedly quite novel, approach to explain the halachic preference of making Kiddush again at home. He explains that in his opinion, ‘V’karasa L’Shabbos Oneg’ has a second, opposite meaning - that in a place where one wants to have an oneg (and any additional eating one does on Shabbos is considered oneg as well) he must also make Kiddush. (This idea, which some refer to as ‘Seudah B’Makom Kiddush,’ would only apply until one has made Kiddush with a full bread Seudah.)

In view of this, Rav Moshe is able to synthesize the opinions of Tosafos and the Rosh with that of the Gaonim. He maintains that Tosafos and the Rosh were referring to the general understanding of the pasuk, that a Seudah for Kiddush requires bread. However, the Gaonim were referring to the secondary understanding of the pasuk, meaning that whenever one wants to eat, one should make Kiddush first. This would include eating Mezonos or even drinking wine, as commonly done at a Kiddush in shul.[31]

It should be clear, however, that according to Rav Moshe, one will not fulfill his full chiyuv of Kiddush B’makom Seudah until making Kiddush again along with a full Seudah.

So the next time you arrive home Shabbos morning to the delicious Seudah waiting, rest assured that by making Kiddush (again) you are partaking in the beautiful mitzvah of “V’karasa L’Shabbos Oneg.”[32]

Postscript: A Double Dilemma: A fascinating corollary to this discussion is another: if one already made Kiddush on Mezonos in shul to fulfill ‘Kiddush B’makom Seudah’ and later, upon returning home has his main Shabbos Seudah, is that main Seudah now considered Seudas Shlishis (‘Shaleshudis’ in the vernacular)? Not just a technical issue, the Steipler Gaon[33] cites a practical halachic ramification of this question – if one forgot to recite Retzei as part of Birkas Hamazon. Generally speaking, as one is mandated in eating Seudos on Shabbos, one is therefore obligated to repeat the whole bentching upon omitting Retzei.[34]

Yet, the exception to the rule might be Seudas Shlishis. As there is a machlokes Rishonim whether it is necessary to have a bread-based meal for Seudas Shlishis, the Tur (O.C. 188: 8)concludes tzarich iyun whether one must repeat Birkas Hamazon upon forgetting Retzei.[35] Practically, the Shulchan Aruch rules that if one completed Bentching of Seudas Shlishis without reciting Retzei, he should not repeat Bentching, as lemaaseh, Seudas Shlishis shares the halachic status of Rosh Chodesh, when it is preferential to wash, but not an outright obligation.

So, if one forgot Retzei in Birkas Hamazon in his main Shabbos meal, which was after he had already partaken of a ‘Mezonos meal’ Kiddush in shul, the Steipler Gaon maintains that he has unwittingly entered a double dilemma. According the Vilna Gaon et al., the Mezonos Kiddush in shul was not considered a Seudah. As such, upon omitting Reztei after the main meal, one would certainly be obligated to repeat Bentching, as it is halachically considered his main Shabbos Seudah.

On the other hand, following the mainstream shittah of the Magen Avraham, that the Mezonos Kiddush was ‘Kiddush B’makom Seudah,’ it is entirely possible that the Kiddush was considered his Shabbos Seudah, and the main Seudah following was halachically considered Seudas Shlishis,[36] and thus quite complicated whether or not Birkas Hamazon need be repeated. The Steipler Gaon concludes that ‘l’dina,tzarich iyun gadol.’ Hence, if this happens to you, he advises washing and making Hamotzi again and then Bentching with Retzei. Utilizing this solution removes all halachic doubt and ensures that there will be no bracha levatallah.[37] Just some more ‘food for thought’ while enjoying your Kiddush.

The author wishes to thank Rabbi Dr. Eliezer Brodt for making available his unpublished ma’amar on topic.

For any questions, comments or for the full Mareh Mekomos / sources, please email the author:

Rabbi Yehuda Spitz, author of M’Shulchan Yehuda on Inyanei Halacha, serves as the Sho’el U'Meishiv and Rosh Chabura of the Ohr Lagolah Halacha Kollel at Yeshivas Ohr Somayach in Yerushalayim. He also currently writes a contemporary halacha column for the Ohr Somayach website titled “Insights Into Halacha”.

Rabbi Spitz’s recent English halacha sefer, “Insights Into Halacha - Food: A Halachic Analysis,” (Mosaica/Feldheim) contains more than 500 pages and features over 30 comprehensive chapters, discussing a myriad of halachic issues relating to food. It is now available online and in bookstores everywhere.

[1]Parashas Yisro (Ch. 20:7-11). Although not exact to the lashon of the Aseres Hadibros featured in Parashas Va’eschanan (Ch. 5: 12), ‘Shamor es Yom HaShabbos Lekadsho’, nevertheless, we know that ‘Shamor V’Zachor B’Dibbur Echad’ (as mentioned in Rav Shlomo Alkabetz’s timeless ‘Lecha Dodi’). In fact, it is precisely this nuance that teaches us the joint obligations of positive and negative commandments (Zachor V’Shamor) on Shabbos, which obligates women the same as men. This was discussed at length in a previous article titled ‘Facts and Formulae for the Forgetful’.

[2]Pesachim (106a).

[3]See Gemara Brachos (20b and 27b), Rambam (Hilchos Shabbos Ch. 29:1 and 4), Sefer HaChinuch (Parashas Yisro: Mitzva 31), Tur and Shulchan Aruch and main commentaries (Orach Chaim 271) at length, and Kitzur Shulchan Aruch (77:1).

[4]Rashbam (Pesachim 106a s.v. amar) citing the Sheiltos D’Rav Achai Gaon (Parashas Yisro: 54). Similar sevaros are given by other Rishonim, including the Meiri and Tosafos Ri”d in their commentaries (Pesachim ad loc.). See also Shulchan Aruch HaRav (Orach Chaim 289:2) and Aruch Hashulchan (ad loc. 3).

[5]This nuance, as well as its practical ramifications, was discussed at great length in a previous article titled ‘Common Kiddush Questions.

[6]Gemara Pesachim (101a). See Rif (Pesachim 20a), Rosh (ad loc. Ch. 10:5), Tosafos (ad loc. 100b s.v. yedei Kiddush), Rambam (Hilchos Shabbos, Ch. 29:8 and 10), and Tur and Shulchan Aruch (Orach Chaim 273: 1).

[7]Rashbam (ad loc. s.v. af) citing Yeshaya (Ch. 58: 13).

[8]Tosafos (Pesachim 101a s.v. ta’eemo) and Rosh (ad loc. Ch. 10: 5). Tur (Orach Chaim 273: 5). See also footnote 12.

[9]Several issues related to what types of water with which one may wash Netillas Yadim were discussed in a previous article titled ‘The Colored Water Caper.’

[10]The importance of Mayim Acharonim was discussed in detail in a previous article titled ‘Mayim Acharonim, Chovah?

[11]Beis Yosef (Orach Chaim 273: 5 s.v. kasvu Hagaonim).

[12]For example, the Derisha (Orach Chaim 269:3 s.v. od) argues that although this shitta of the Gaonim would fit with the Rambam’s (Hilchos Brachos, Ch. 4:1) and the Rashbam’s (Pesachim 101b s.v. aval) definition of Seudah, nevertheless, it cannot fit with the shitta of Tosafos and the Rosh; an assessment later shared by Rabbi Akiva Eiger (Orach Chaim 273:7), the Mekor Chaim (ad loc.), the Tosefes Shabbos (ad loc. 11), and the Erech Hashulchan (ad loc.). Rav Yitzchok Elchanan Spektor (Shu”t Ein Yitzchok Orach Chaim, 12:7), Rav Yitzchok Isaac Chaver (Shu”t Binyan Olam 8), and Rav Yaakov Kamenetsky as well (Emes L’Yaakov on Pesachim 51b and Emes L’Yaakov on Tur and Shulchan Aruch, Orach Chaim 273:5) conclude that the Beis Yosef’s position is tzarich iyun. Additionally, Rav Nitronaei Gaon (Shu”t Hagaonim,Orach Chaim 79), and as well as other Rishonim, including Rabbeinu Yonah (Ch. 7; 36b in the Rif’s pages, s.v. Birkas), the Mordechai (cited by the Haghos Maimoniyos, Hilchos Shabbos, Ch. 29:80), and the Rashba (Shu”t vol. 5:212; and in his commentary to Brachos 51b s.v. shehayayin), maintain that Seudah can only mean a bread-based meal. However, several Acharonim do suggest different mehalchim to answer up these kushyos; see the Maharsham’s Daas Torah (Orach Chaim 273:5 s.v. kasvu Hagaonim), Shu”t Beis She’arim (96), and Shu”t Minchas Yitzchok (vol. 8:46, 2) for possible solutions. Rav Moshe Feinstein as well (Shu”t Igros Moshe, Orach Chaim vol. 4: 63, 7 and 8; cited later on in the article) proposes a novel approach to solve the issues.

[13]Although the Shulchan Aruch and Rema made no mention of mandating an additional cup of wine, implying that the first one is sufficient for the ‘Seudah’ aspect as well, nonetheless the Be’er Heitiv (Orach Chaim 273:6), cites the Levush (ad loc. 5), Bach (ad loc. 3 s.v. aval), and Taz (ad loc. 4), [the Magen Avraham (ad loc. 12), Elyah Rabbah (ad loc. 8), and Perisha (ad loc. 3) imply this way as well] who assert that an additional cup of wine (or at least another reviis), aside for the one drunk as Kiddush, must be drunk as the Seudah. On the other hand, there are those, including the Even HaOzer (ad loc.), Chida (Birkei Yosef ad loc. 2), and Aruch Hashulchan (ad loc. 9), [the Ginas Veradim (Shu”t Orach Chaim 3: 20) and Chayei Adam (vol. 2, 6:22) imply this way as well] who defend the one cup practice as being considered Kiddush B’makom Seudah. The Shulchan Aruch HaRav (ad loc. 9) writes that ‘le’ais hatzorech’, one may rely upon the more lenient opinion, yet concludes that it is certainly preferential if at all possible to drink an extra cup to be yotzei l’divrei hakol. The Kaf Hachaim (ad loc. 38) concludes similarly, that “kivan d’ika plugsa bazeh, yesh lehachmir, v’ain lehakel ela b’shaas hadchak”. Interestingly, the Mishnah Berurah (ad loc. 27) simply cites both sides of this debate. Yet, in his Sha’ar Hatziyun (ad loc. 29) he concludes that one may only rely on using one cup at the Shabbos day Kiddush - and if one has very limited wine.

[14]Magen Avraham (Orach Chaim 273:11).

[15]Or is it Hage fen? This was discussed in a previous article titled ‘Ge shemor Ga shem?.

[16]Hamega’eish: Hamotzi, Mezonos, Hagafen, Ha’eitz, Ha’adamah, Shehakol. See Orach Chaim (211).

[17]See Shu”t Ginas Veradim (Orach Chaim 3:12), Birkei Yosef (Orach Chaim 273:2 and 6), Be’er Heitiv (ad loc. 7), Shaarei Teshuva (ad loc. 7), Shulchan Aruch Harav (ad loc. 7; interestingly, in the next siman 274:5, he writes that even so, one must have another Seudah on bread, as the Mezonos at a Kiddush does not constitute a meal to fulfill one of his three Shabbos Seudah obligations), Pri Megadim (ad loc. Eishel Avraham 11), Chayei Adam (vol. 2, 6:22), Matteh Efraim (597: 2), Kitzur Shulchan Aruch (77: 14), Ben Ish Chai (Year 2, Parashas Bereishis 7), Aruch Hashulchan (Orach Chaim 273:8), Mishnah Berurah (ad loc. 25), and Kaf Hachaim (ad loc. 41). Many contemporary poskim as well, including Rav Shlomo Zalman Auerbach (see Halichos Shlomo on Moadim vol. 1, Ch. 1: footnote 72 and Va’aleihu Lo Yibol vol. 1, pg. 141), Rav Yosef Shalom Elyashiv (Kovetz Teshuvos vol. 1:24 s.v. umei), the Minchas Yitzchak (Shu”t vol. 3:13, 7), Rav Yisrael Yaakov Fischer (Halichos Even Yisrael, Shabbos vol. 1, Ch. 14:9 and 25:3), and Rav Moshe Feinstein (see footnote 30), rule that the ikar halachah follows the ruling of the Magen Avraham that one may lechatchillah make Kiddush with Minei Mezonos.

[18]Rabbi Akiva Eiger (Orach Chaim 273:7 and 9) and Tosefes Shabbos (ad loc. 11), based on the words of Talmidei Rabbeinu Yonah in Brachos (ibid.) that the Magen Avraham himself cites in Orach Chaim (188: 9), strongly questions the idea of considering wine to be ‘Makom Seudah.’ Additionally, Rav Eiger understands that the machlokes between the Gaonim and Tosafos and the Rosh cannot be easily synthesized, as it should depend on their own respective opinions regarding whether fruit from the Shivas Haminim require their own brachah acharonah of ‘Al Hapeiros.’ It would therefore stand to reason that the Rosh simply cannot hold of utilizing wine as a ‘Seudah.’ The Mishnah Berurah cites this opinion strongly and concludes that practically one may only rely on using wine as ‘Makom Seudahb’makom hadchak (in extenuating circumstances). This means that although the permissibility to make Kiddush on Mezonos is based on the allowance to using wine as ‘Makom Seudah,’ nonetheless, and quite interestingly, the Mishnah Berurah seemingly prefers Mezonos’s use over wines. The Gr”a’s shitta is recorded in Ma’aseh Rav (122) and cited in Biur Halacha (275:5 s.v. kasvu), even though in his own Biur HaGr”a (ad loc. s.v. kasvu and v’davka) he seems to imply like the Shittas HaGaonim and Magen Avraham. See also footnote 12.

[19]Although, in his Mishnah Berurah (ibid.), the Chofetz Chaim fully rules like the Magen Avraham, on the other hand, in his Biur Halacha (ibid.), he only cites the Vilna Gaon’s opinion, implying his predilection to be machmir for this shittah. This is similar to the Pri Megadim, who, likewise, in Orach Chaim 273 (ibid.) rules like the Mogen Avraham, but in Orach Chaim 271 (Eishel Avraham 3), he writes that ‘mikol makom lechatchilla tov pas.’ The Aruch Hashulchan (ibid.) as well, although stating that the ikar halachah follows the Magen Avraham’s ruling, nevertheless concludes that it is preferred (mehadrin) to be makpid on only making Kiddush with a full Seudah. Several contemporary sefarim including Shemiras Shabbos Kehilchasa (vol. 2, Ch. 54:22) and Yalkut Yosef (Kitzur Shulchan Aruch, Orach Chaim 273:9, in the parenthesis) write that indeed it is preferable to be machmir on making Kiddush with actual pas as the Seudah. It is recorded (Orchos Rabbeinu vol. 1, pg. 125) that the Chazon Ish was machmir for the Gr”a’s shittah for himself, but not for others. See also footnote 12.

[20]See, for example, Minchas Asher on Pesachim (77) and Minchas Asher on Zemiras LeShabbos (Kiddush B’Makom Seudah pg. 148-152), who questions the Magen Avraham’s jump in logic in the shittas HaGaonim from the allowance of wine as a Seudah to Mezonos, and argues that possibly the Gaonim only allowed wine as it is considered the beginning of a Seudah since it whets the appetite (Gemara Pesachim 107b; and citing proof from the Perisha, Orach Chaim 269), as opposed to ‘Minei Targima.’ He therefore concludes that indeed one should not rely on making Kiddush on Minei Mezonos.

[21]Shu”t Ein Yitzchok (Orach Chaim, 12:11). See also the lashon in the Chayei Adam (vol. 2, 6:22; in brackets, citing the Elyah Rabbah), Kitzur Shulchan Aruch (77:14), and Mishnah Berura (273: 26 and Shaar Hatziyun ad loc. 29), based on the precedent of the lenient ruling of the Shiltei Gibborim (Pesachim 20a: 1) regarding utilizing fruit as ‘Makom Seudah’, who all strongly imply this way as well, that there is more room for leniency regarding the Shabbos Day Kiddush as it is only mandated M’Derabbanan. The Ginas Veradim (Shu”t ibid.) also concludes similarly. See also Shulchan Aruch (Orach Chaim 272: 9), citing the Rosh (Pesachim 107a) regarding using ‘Chamar Medina’ for Kiddush, who due to similar reasoning only allows it to be used for the Rabbinically mandated Shabbos day Kiddush and not the Biblical Friday night Kiddush. An additional possible reason for being more lenient with the Shabbos day Kiddush than on Friday night is that perhaps we can also add as a snif the shittah of the Raavad (Glosses to the Rambam, Hilchos Shabbos Ch. 29:10), who holds that one is allowed to eat prior to Kiddush on Shabbos day.

[22]A somewhat similar approach is put forth by Rav Yosef Dov (JB) Soloveitchik, Rosh Yeshivas Rabbeinu Yitzchak Elchanan (YU), as cited by his talmid, Rav Herschel Schachter (Eretz Hatzvi, 5: end 10). He maintains that the reason why the “minhag ha’olam” is to make Kiddush on Mezonos on Shabbos morning is due to a ‘Sfeik Sfeika’ – perhaps the halacha follows the Gaonim, and perhaps the halacha follows the Raavad (cited in the previous footnote), that one is permitted to eat before the Shabbos day Kiddush. Although the Magen Avraham does not distinguish between the night and day Kiddush in the shittah of the Gaonim, and the Shulchan Aruch (O.C. 289:1) rules against the Raavad’s opinion – and mandates Shabbos day Kiddush prior to eating, nonetheless, Rav Soloveitchik is quoted as maintaining this tziruf hashittos as the rationale behind the “minhag haolam.” The upshot of this is that Kiddush will need to be recited again a full Hamotzi Seudah, as the Raavad only holds that one may eat before Kiddush, but still mandates Kiddush to be recited. Hence, as the halacha may follow the Gr”a, accordingly, Kiddush on Mezonos is an allowance, but does not necessarily fulfill one’s Kiddush B‘makom Seudah obligation.

[23]See Shu”t Ein Yitzchok (ibid. 5) who explains at length that the obligation for Kiddush on Yom Tov is derabbanan. The Chazon Ish’s ruling for making Kiddush on Mezonos as the Seudah on Simchas Torah night is widely known; it is cited in Orchos Rabbeinu (new print; vol. 1, ‘Hora’os m’Maran HaChazon Ish’, pg. 423: 36), and Piskei Teshuvos (273: end footnote 68), and is customary in many Yeshivos.

[24]Shu”t Salmas Chaim (old print vol. 1:59; new print Orach Chaim 255), Shu”t Teshuvos V’Hanhagos (vol. 1:264), and Moadim U’Zmanim (vol. 3:243). This is similar to Rav Yosef Eliyahu Henkin’s assessment (Shu”t Gevuros Eliyahu vol. 1:83 s.v. umatzinu) of why one who makes Kiddush as part of davening in shul is not yotzei and nevertheless needs to make Kiddush again at his Seudah at home. Rav Henkin explains that ‘lo yotzai’ here does not mean that he was not allowed to do so, but rather that he still has not yet fulfilled his obligation; as such, he must be metaken and mashlim his chiyuv by making Kiddush at his Seudah. However, Rav Asher Weiss (Minchas Asher ibid.) maintains that this is not a proper solution, as then Kiddush would be made as part of two separate and distinct Seudos, whereas in his opinion, the Tur and Shulchan Aruch imply in the Shittas HaGaonim that it should be part and parcel of one (albeit possibly extended) meal.

[25]Rav Shlomo Zalman’s hanhagah is cited by his talmid, Rav Avigdor Nebenzahl, in his sefer Yerushalayim B’Moadeha (Shabbos vol. 2:124).

[26]Kovetz Kol HaTorah (vol. 42, Nissan 5757, pg. 22:22; ‘Leket mei’Hanhagos v’Hora’os HaGaava”d zt”l [Minchas Yitzchak] B’Inyanei Hilchos Shabbos’).

[27]Shu”t Betzeil Hachochma (vol. 5:117).

[28]Cited in Rav Herschel Schachter’s Eretz HaTzvi (5: end 10 s.v. ulf divrei Rabbeinu; his rationale is explained in an earlier footnote). Thanks are due to Rabbi Yaakov Luban for providing this source.

[29]On the other hand, Rav Yisrael Yaakov Fischer (Halichos Even Yisrael, Shabbos vol. 1, Ch. 25:3 and footnote 4) maintained that not only is making Kiddush a second time not necessary, he held ‘ain lehachmir b’zeh,’ because ‘yehei nireh k’ilu achal m’kodem b’lo Kiddush.

[30]Shu”t Igros Moshe (Orach Chaim vol. 4:63, 7 and 8). See also Shu”t Vedibarta Bam (vol. 1:72), quoting Rav Dovid Feinstein. According to this understanding, Rav Moshe also rules that the ikar din follows the Magen Avraham, that one may make Kiddush on Mezonos. However one will not have fully fulfilled his obligation of Kiddush B’Makom Seudah until making Kiddush again as part of a full bread-based Seudah. Interestingly, the Miluim in the new edition of Maaseh Rav (Weinreb edition; pg. 337:122) cites that ‘Yesh Omrim’ that the Gr”a’s kavanna was actually akin to Rav Moshe’s novel approach, and technically one can fulfill his Kiddush obligation with Mezonos, but will need to make another at home with Pas, and not as he is widely quoted, that one is not yotzei at all unless reciting Kiddush as part of a bread-based Seudah.

[31]There are several interesting theoretical upshots to Rav Moshe’s explanation. The Rambam (Hilchos Shabbos Ch. 30:9) writes that one should be koveya his Seudas Shlishis on wine. The Tur (O.C. 291:4) implies that he understands the Rambam to be mandating Kiddush, and counters, citing his father, the Rosh that it is not necessary. Rav Yosef Karo, both in his Kessef Mishnah commentary on the Rambam (ad loc.), and Beis Yosef commentary on the Tur (ad loc.), argues that in his opinion that was not truly the Rambam’s intent, but rather that one should also drink wine at Seudas Shlishis as he would at the other Seudos, as he considers it a full Shabbos Seudah. He then cites a long list of Rishonim who state that Kiddush is not required at Seudas Shlishis, and actually explicitly rules that way in his Shulchan Aruch (ad loc.). It has been opined that Rav Moshe’s explanation of “V’karasa L’Shabbos Oneg” might help us understand the Rambam’s shittah (according to those who hold that that is his opinion) of possibly mandating Kiddush for Seudas Shlishis as well, although not the practical halacha. An additional related inyan is that of whether one who heard Kiddush on Mezonos but did not actually eat, has fulfilled his obligation of Kiddush. Many Acharonim, including the Chida (Birkei Yosef O.C. 273:2, 6), Shaarei Teshuva (ad loc. 7), and Mishnah Berurah (ad loc. 26) rule that he has not, as he has not partaken of any part of Kiddush. Yet, the Yalkut Me’am Loez (Parashas Yisro Ch. 20:8) writes that he has. Likewise, it has been posited that Rav Moshe’s double explanation of “V’karasa L’Shabbos Oneg,” may explain the differing rationales of the Me’am Loez’s seemingly puzzling position, as well as that of the Acharonim, whether Kiddush is a Tenai in the din of Seudah or vice versa.Practically, several contemporary authorities including Rav Ovadiah Yosef (Shu”t Yabea Omer vol. 2, O.C. 19) and the B’tzeil Hachochmah (Shu”t vol. 4:2 and vol. 5:115-117) ruled that one may only be lenient b’shaas hadchak regarding the Rabbinic Shabbos day Kiddush, utilizing the Me’am Loez’s position as a snif lehakel. Thanks are due to Rabbi Yaakov Luban and Rabbi Yochonon Donn for pointing out these hypothetical nafka minahs of Rav Moshe’s understanding of the inyan.

[32]For more issues related to Kiddush B’makom Seudah see R’ Zvi Ryzman’s Ratz KaTzvi (vol. 1: 11; at length) as well as Shu”t Divrei Pinchas (vol. 1: 27).

[33]Kehillas Yaakov (Brachos 25; 16 in the old print; see also Rav Asher Sonnenfeld’s recent Shaarei Osher on Chagim U’Zmanim vol. 3: 22 s.v. u’tfei and 110, and Shaarei Osher on Chag HaPesach 44).

[34]This was discussed at length in a previous article titled ‘Facts and Formulae for the Forgetful.’

[35]Tur (O.C. 188: 8). Although the Tur himself, as well as the Shulchan Aruch (O.C. 291:4 and 5), conclude that one should wash for Seudas Shlishis, due to the three times the Torah states ‘Hayom’ in the Parashas HaMann.

[36]Although the Rema (O.C. 291:2) concludes that lechatchilla one should daven Mincha prior to eating Seudas Shlishis, nevertheless, one m’dina is still yotzei his chiyuv after Zman Mincha Gedolah.

[37]However, Orchos Rabbeinu (new edition; vol. 1, pg. 237, 8) relates that after asking the Chazon Ish, the Steipler Gaon later changed his psak, ruling that lemaaseh it is ‘mestaver’ that one would indeed be yotzei his chiyuv of Seudas Shacharis with Mezonos, and would therefore not repeat Birkas Hamazon for forgetting Retzei at the later full Seudah.

Disclaimer: This is not a comprehensive guide, rather a brief summary to raise awareness of the issues. In any real case one should ask a competent Halachic authority.

L'iluy Nishmas the Rosh HaYeshiva - Rav Chonoh Menachem Mendel ben R' Yechezkel Shraga, Rav Yaakov Yeshaya ben R' Boruch Yehuda.

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