A woman can fulfill the obligation of tefillah by reciting Tehillim in a situation where she is unable to pray the Amidah prayer.
Sources and Explanations
The mitzvah of tefillah is brought in the Sefer HaChinuch (mitzvah 433) as follows: “It is a positive commandment to serve Hashem, may He be blessed, as it says, ‘And Him you shall serve’ (Devarim 6:13). This mitzvah is repeated several times, as it says, ‘And you shall serve Hashem your God’ (Shemot 23:25), and elsewhere it says, ‘And Him you shall serve’ (Devarim 13:5), and elsewhere, ‘And to serve Him with all your heart’ (Devarim 11:13). The Rambam, of blessed memory, wrote (Positive Commandment 5) that although this mitzvah is one of the all-encompassing mitzvot, that is, those that encompass the entire Torah, for the service of God includes all the mitzvot, there is also in it a specific element, namely, that God commands us to pray to Him. As they said in the Sifrei (Vehayah im shamoa), ‘And to serve Him with all your heart’: what is service of the heart? This is prayer. And in the Mishnah of Rabbi Eliezer the son of Rabbi Yosei HaGelili they said: From where do we know that prayer is fundamentally among the mitzvot? From here: ‘Hashem your God you shall fear, and Him you shall serve’ (Devarim 6:13). However, we have no fixed time in the Torah for performing this mitzvah; therefore our Rabbis are in doubt regarding the matter. The Rambam, of blessed memory, wrote in his great work (Hilchot Tefillah 1:2) that it is a mitzvah to pray every day. The Ramban, of blessed memory (in Sefer HaMitzvot, Positive Commandment 5), took issue with him and said that the Torah did not command us to pray every day, nor even every week, and did not designate any time for it at all. And Chazal, of blessed memory, always say ‘prayer is rabbinic’ (Berachot 21a); and he says, as one who is in doubt, that the mitzvah is to pray and cry out before God, blessed be He, at a time of distress. The Rambam, of blessed memory, himself also wrote that neither the number of prayers nor the wording of prayer is from the Torah, and prayer has no fixed time in the day from the Torah; but nevertheless, the Torah obligation is to supplicate God every day and to give thanks before Him, for all dominion is His, as is the ability to fulfill every request.” End quote.
Therefore, to fulfill the Torah-level mitzvah of tefillah, a short private prayer suffices, in accordance with one’s fluency of speech, or some supplication, as the Rambam writes (Hilchot Tefillah 1:3–4): “If he was accustomed, he would increase in supplication and request. And if he was of uncircumcised lips (inarticulate), he would speak according to his ability and whenever he wished. Likewise, the number of prayers was each according to his ability: some would pray once a day, and some would pray many times. And all would pray facing the Sanctuary, wherever they were. And so the matter always was from Moshe Rabbeinu until Ezra. Once Israel was exiled in the days of the wicked Nebuchadnezzar, they mingled with Persia, Greece, and the other nations, and children were born to them in the lands of the gentiles, and the language of those children became confused, and the language of each one was a mixture of many languages; and when he spoke, he could not express all his needs in one language except in a garbled manner, as it says, ‘And their children spoke half in Ashdodite etc.,’ and they did not know how to speak Judean, but rather in the language of each people. Because of this, when one of them would pray, his speech would fall short in asking for his needs or in declaring the praise of Hakadosh Baruch Hu in the Holy Tongue, unless other languages were mixed in with it. When Ezra and his court saw this, they arose and instituted for them eighteen blessings in order: the first three are praise of Hashem, the last three are thanksgiving, and the middle ones contain requests for all things, which are like general categories for all the desires of each individual and for the needs of the community — all of them, so that they would be arranged in everyone’s mouth and they would learn them, and the prayer of these stammerers would be a complete prayer like the prayer of those of eloquent speech. And for this reason they instituted all the blessings and prayers arranged in the mouth of all Israel, so that the content of each blessing would be arranged in the mouth of the stammerer.” End quote of the Rambam.
One must investigate whether, after Chazal instituted praying the eighteen blessings (Shemoneh Esreh), a person can still fulfill his obligation bedi’eved (after the fact) with a request as before the enactment, and the enactment would only be a lechatchilah (ideal) requirement.
Rav Moshe Sternbuch discusses this question in Teshuvot VeHanhagot (vol. 5, siman 38), and writes: “I was in doubt whether one fulfills the positive commandment even today with any prayer and wording he wishes, or whether we say that Chazal uprooted it so that even on the Torah level one does not fulfill the mitzvah except with the Shemoneh Esreh prayer, and Chazal have the power to remove from him a Torah mitzvah, as we find in Tosafot Sukkah (3a, s.v. de’amar) that Chazal uprooted the mitzvah in a case where one eats in the sukkah while his table is inside the house, so that even on the Torah level he has not fulfilled the positive commandment. It seems that one can bring a proof that even on the Torah level one fulfills the obligation today only with Shemoneh Esreh, for in Eruvin (65a) they said that one who comes from a journey should not pray for three days, and so rules the Rambam (Hilchot Tefillah 4:15): ‘Therefore, one who comes from a journey and is tired or distressed is forbidden to pray until his mind is settled. The Sages said: he should wait three days and afterwards pray.’ This is difficult: granted that he cannot pray Shemoneh Esreh as instituted by Chazal, nevertheless he has no license to neglect the positive commandment, and we should have obligated him to pray some prayer with praise, request, and thanksgiving, to at least fulfill his Torah obligation. Therefore it seems that the Torah mitzvah is fulfilled only with Shemoneh Esreh as instituted by Chazal, and if he cannot pray Shemoneh Esreh he is exempt, etc.”
At the conclusion of his words he distinguished: although with whatever he prays with intention of the heart — some prayer or supplication, such as reciting Tehillim — he fulfills the positive commandment, especially if he intends or explicitly says that he wishes thereby to fulfill the mitzvah of serving Hashem through prayer, and then it is a time of greater favor; nevertheless, he does not thereby discharge the obligation of the mitzvah of tefillah except through the Shemoneh Esreh prayer as instituted by Chazal.
These words of his were difficult for me, since women are the same as men in the obligation of tefillah, for the mitzvah of tefillah is not a time-bound positive commandment, as the Shulchan Aruch writes (Orach Chaim 106:1): “Women and slaves, although they are exempt from reciting Shema, are obligated in tefillah, because it is a positive commandment.” The Mishnah Berurah explains (106:4): “All this is only according to the opinion of the Rambam, that only the times of prayer are from the words of the Scribes, but the essential mitzvah of tefillah is from the Torah, as it says, ‘And to serve Him with all your heart’ — what service is in the heart? You must say this is prayer — except that it has no set wording from the Torah, and one may pray in any wording he wishes and at any time he wishes, and once he has prayed once during the day or the night he has fulfilled his Torah obligation. The Magen Avraham writes that based on this reasoning most women are accustomed not to pray Shemoneh Esreh regularly morning and evening, because immediately in the morning, close to washing the hands, they say some request, and on the Torah level they fulfill their obligation with this, and it is possible that even the Sages did not obligate more. But the opinion of the Ramban is that the essential mitzvah of tefillah is from the words of the Scribes, namely the Men of the Great Assembly, who instituted eighteen blessings in order, to pray them at Shacharit and Minchah as an obligation, and Arvit as optional. And although it is a time-bound positive commandment from the words of the Scribes, and women are exempt from every time-bound positive commandment, even rabbinic ones such as Kiddush Levanah, nevertheless they obligated them in the Shacharit and Minchah prayers like men, since prayer is a plea for mercy. And this is the primary view, for so is the opinion of most poskim, and so decided the Sha’agat Aryeh; therefore women should be cautioned to pray Shemoneh Esreh.”
From the ruling of the Magen Avraham, who was lenient for women to say some request, and with this they fulfill the Shemoneh Esreh prayer, and who wrote that it is possible that the Sages did not obligate more than this, I found difficulty with the words of the Teshuvot VeHanhagot above, for it is clear that there is no difference in the nature of the obligation between a man and a woman in positive commandments that are not time-bound, such as the above mitzvah of tefillah; and here before us is the Magen Avraham explicitly writing that when it is not possible to pray a full Shemoneh Esreh prayer, one should say some request and thereby fulfill his Torah obligation. [And although Halichot Shlomo (chapter 2, halacha 3) writes that although the prohibition of eating before prayer applies to a woman as to a man, nevertheless in the half hour before dawn a woman is permitted to eat, since the obligation of a woman’s prayer is not like that of a man, end of his words, it seems that his reason is that the Sages’ prohibition of eating a half hour before dawn pertains only to one who is obligated lechatchilah to pray a complete prayer, and not to a woman, who is permitted lechatchilah, where necessary, to say some request.]
Furthermore, his words are explicitly contradicted by the ruling of the Radbaz (Responsa, vol. 6, siman 2,176) that one who travels on the road for many days and cannot pray Shemoneh Esreh fulfills the Torah obligation of tefillah by saying Tefillat HaDerech (the traveler’s prayer). He added that therefore he must recite it every single day, and he thereby fulfills the obligation of tefillah from the Torah, as it is written, ‘And to serve Him with all your heart,’ and Chazal said: What is service of the heart? This is prayer. And the number of prayers is not from the Torah, and the obligation of the prayer that we pray is not from the Torah, and prayer has no fixed time from the Torah; therefore this person who sets out on the road, who asked for his needs from Hakadosh Baruch Hu, has fulfilled the obligation of tefillah from the Torah; but nevertheless he must pray it every day, similar to what they instituted for us to pray every day.
Likewise, contrary to the words of the Teshuvot VeHanhagot, it is found in the Yeshuot Yaakov (beginning of siman 106), who writes that a ba’al keri (one who has had a seminal emission) fulfills the Torah obligation of tefillah by reciting Shema and its blessings, and even by reciting Birchot HaTorah (the blessings over the Torah) he fulfills his Torah obligation.
In practice, although the Mishnah Berurah decided to obligate women in Shemoneh Esreh in accordance with the Ramban and most poskim, those who came after him wrote that in practice the custom is to be lenient, that one short prayer suffices, in accordance with the Magen Avraham. See that Halichot Shlomo by Rabbi Shlomo Zalman Auerbach writes so (chapter 2, note 5). And in Or LeTzion (vol. 2, chapter 7, end of note 24) he writes: “A woman burdened with children and occupied with this all day is completely exempt from prayer. The same applies to a man: if his wife is not at home, for example she went to give birth, and the husband must take care of the children and does not find time to pray, he is exempt from prayer because he is engaged in a mitzvah, and he is not even obligated in make-up prayers (tashlumin).” And Rabbi Eliyahu Falk in Responsa Machazeh Eliyahu (siman 19, se’if katan 14) writes: “I heard in the name of the Chazon Ish zt”l that when he was asked regarding the obligation of women in prayer, he replied that women burdened with children are included among those mentioned in Eruvin (65a), that anyone whose mind is not settled should not pray. Likewise, women whose minds are not settled — there is great room to be lenient for them to fulfill their obligation with a short prayer … since in any case there is the opinion of the Magen Avraham that one may find merit for them.” And see likewise in Halichot Bat Yisrael (chapter 2, note 2) in the name of Rav Yaakov Kamenetsky.
Well known is the testimony of Rabbi Aryeh Leib, the son of the Chafetz Chaim (cited in Sichot HaChafetz Chaim, vol. 1, ot 27): “My mother, of blessed memory, hardly prayed at all as long as we had not left her care, telling me that my father exempted her from this because she was occupied with raising her children.”
Therefore, one may say in practice that for a woman whose time is not her own to pray a proper tefillah, it suffices to pray briefly, or, instead of this, to say as a short prayer chapters of Tehillim that are in the manner of supplication, request, and thanksgiving, and thereby she fulfills her obligation.
From the sefer “Shaf Veyativ – Laws of Saying Tehillim” by Rabbi Shay Tahan, Chapter 4: Laws Concerning Those Who Say Tehillim, Halacha 10 (p. 53 in the print edition). Translated from the Hebrew original.
