"Thus shalt thou say to the house of Jacob"—These are the women. … Why were women [addressed] first? Because they are alacritous in the fulfillment of commandments.
SHEMOT RABBAH 28:2
The feminist movement has fostered significant sociological and attitudinal changes. It is not at all surprising that women, in examining their role in every area of life, have also turned their attention to their obligations and prerogatives within Jewish tradition. The frustration and denial suffered by women within society at large in the broad spectrum of human endeavor has engendered concerted efforts to break loose from stereotypical roles and to seek parity in all matters. Little wonder, then, that similar demands are advanced with regard to religious observance and practice as well.
This phenomenon has given rise to a host of questions raised by women seeking various avenues of religious expression heretofore not associated in Jewish tradition with the role of women. Rabbi Moses Feinstein, Iggerot Mosheh, Oraḥ Hayyim, IV, no. 49, has astutely noted that, at times, the specific question raised is not at all the real issue. The halakhic factors auguring for an affirmative or for a negative response fade into insignificance when the question itself belies an underlying rejection of the received traditions and teachings of Judaism.
Fortunately, in many instances, this is not the case. For many women, the feminist movement has spawned reflection rather than rejection. Religious introspection and self-analysis with a view to seeking higher levels of spiritual awareness and enhanced observance are to be applauded. Thus, the newly awakened assertiveness of women in our society may well become a positive tool leading to their increased involvement in the religious life of the Jewish community. It is imperative that this singular opportunity be seized and be utilized to maximum advantage in fostering the spiritual enrichment of all members of the community.
Judaism does not espouse a unisex view of social roles and endeavors; rather, it assigns males and females differing obligations and diverse modes of religious expression. But, by no means, does such role differentiation reflect denigration of the spiritual capacities and aspirations of the female. Halakhah makes demands of women, just as it does of men. The demands may not be identical but they are certainly not inferior in significance. Problems concerning the obligations of women were always given as much attention by rabbinic scholars as those concerning religious practices associated with males. The charge that male decisors do not regard the questions posed by female interlocutors with sufficient seriousness is a canard unworthy of those who give expression to it.
The Torah and its Halakhah are objective. As such, there cannot be a male versus a female perspective. Halakhic scholars are duty-bound to examine every sincerely posed question on its merits. Rabbinic leaders are duty-bound to encourage maximal spiritual development on the part of every Jew and of every Jewess. But, at the same time, it remains their duty to advise and to counsel, to admonish and to exhort, and to serve as mentors in guiding religious yearnings in channels fully consonant with Jewish law and tradition.
In the wake of the feminist movement and the desire of women to seek more fulfilling roles in all aspects of community life the Jewish community has experienced a proliferation of women's prayer groups. Only women are invited to participate and women themselves conduct the service in its entirety. Women committed to observance of Halakhah are careful not to recite kaddish, kedushah and other portions of the service which require a minyan, i.e., a quorum of ten males, and which are omitted when praying privately. Many of the organizers and participants in such groups are sincerely motivated by a desire for active participation in what they perceive as a meaningful and edifying religious experience. Nevertheless, there is no gainsaying the fact that no rabbinic authority of stature has been willing to endorse this innovation in the religious life of our community. At best, the reaction is unenthusiastic; at worst, the reaction is outright condemnation as violation of the halakhic norm.1For published reactions see R. Moses Feinstein, Iggerot Mosheh, Oraḥ Ḥayyim, IV, no. 59; R. Joseph B. Soloveichick, quoted by R. Moshe Meiselman, Jewish Woman and Jewish Law (New York, 1978), p. 19, note 64 and R. Herschel Schachter, Bet Yiẓḥak, XVII (5745), 118-35. There are a number of considerations which may or may not rise to the order of a halakhic prohibition but which certainly should inform the formulation of "public policy" regarding this highly sensitive issue.
It is somewhat ironic that feminists have introduced a hitherto unknown element of sexism into the realm of prayer. Tefillah be-zibbur (i.e., prayer with a minyan) may be a male responsibility, but females were never excluded. To be sure, a meḥizah or wall separates the sexes, but the experience of praying as a zibbur (formal community) has always been shared by all. Women may join male minyanim but the reverse is not the case. The services conducted by female groups and led by female officiants simply do not qualify as tefillah be-zibbur. Women whose obligation is entirely individual and personal in nature may gather together and pray as a group of individuals, not a zibbur. Males have an obligation of tefillah be-zibbur which effectively precludes their participation in women's minyanim—even from behind a meḥizah. Moreover, a female officiant quite understandably desires to serve not only as a sheliaḥ zibbur but also as a ḥazanit and hence does not merely recite the prayers aloud but sings or chants in a melodious manner. The singing—even of prayers and psalms—presents serious problems of kol ishah (women's song) for a male participant.
There is no question that many women who participate in women's prayer groups are highly sincere and are prompted by the loftiest of motives. Nevertheless, one can only conclude that their rabbinic mentors have misled them by reason of the latter's own lack of erudition. It is true that women have no obligation with regard to tefillah be-zibbur. According to many authorities, they are nevertheless obligated to pray at least twice daily—shaḥarit and minḥah. A woman can satisfy that obligation either by praying privately or with a minyan. If she chooses to pray privately she is in no way remiss; but if she does pray with a minyan she enjoys the kiyyum (fulfillment) of tefillah be-zibbur. Not the least of the advantages of tefillah be-zibbur is the assurance that "the prayer of the community is always heard; even if there are transgressors among them, the Holy One, blessed be He, does not disdain the prayer of the multitude" (Rambam, Hilkhot Tefillah 8:1).
This point may be illustrated by the following analogy: No one is obligated to invest funds in order to earn a profit. Many people have no spare cash to invest. Others have neither the inclination nor the desire to pursue investment opportunities. But consider the person who does have both the funds and the desire to invest. He or she is offered two separate investment opportunities. Each is entirely risk-free and open-ended in terms of potential profit. The second is tied to the first in the sense that it is guaranteed to yield no less a return then the first but carries the additional advantage of a guaranteed minimum return. Which offer should the investor choose? Since the first investment opportunity carries no advantage over the second, while the second bears the distinct advantage of a guaranteed return, the choice is obvious. An investment counselor who recommends the first investment over the second has not only offered poor advice but has transgressed the biblical commandment "and thou shalt not place a stumbling block before the blind" (Leviticus 19:14). The Sages declare that this prohibition is directed against offering imprudent advice to a "blind" (i.e., an uninformed) person in need of guidance.
That women enjoy a kiyyum of tefillah be-zibbur and receive reward for participation in communal worship is evident from an anecdote recorded in Yalkut Shim'oni, Parshat Ekev, no. 871. An aged woman came before R. Yose ben Halafta, and told him that her life had become inordinately burdensome and, accordingly, she sought his counsel in finding a way in which her demise might be hastened. Upon inquiry, R. Yose ben Halafta discovered that the woman was meticulous in attending synagogue services daily. Thereupon he advised her to refrain from worshipping in the synagogue for three consecutive days. She did so and on the third day she became terminally ill. It is clear from this narrative that the woman was not advised to refrain from prayer altogether; indeed, that would have constituted a transgression and could not be countenanced. Rather, the woman was counseled to abstain from communal prayer in the synagogue on the assumption that it was due to the merit acquired through communal prayer that she was granted longevity and that, were she to desist from communal prayer, such compensation would no longer be forthcoming.2The comments of the thirteenth-century talmudic commentator, R. Menachem Me’iri, Rosh ha-Shanah 28a, certainly reflect recognition that women may share in the kiyyum of tefillah be-ẓibbur. Me’iri’s remarks that women who pray in “a synagogue separate unto themselves” do not share in communal prayer. Clearly, the inference to be drawn from this comment is that, when praying in the synagogue proper, they do enjoy the benefits of tefillah be-ẓibbur. The categorization “a synagogue separate unto themselves” does not apply to women’s sections of contemporary synagogues. Nor, apparently, was his comment germane with regard to synagogues in use during the talmudic period. Indeed, Me’iri explicitly limits his comment to “our women.”
As noted earlier, a woman whose spirit fails to move her to participate in communal prayer may pray at home. But a woman willing to invest the time, effort and spiritual energy in search of a higher form of prayer should recognize that the time and effort invested in attending synagogue services will certainly yield no less a return than she will reap from participation in a women's prayer group and that, while synagogue attendance carries a guaranteed return, other modes of prayer do not. "The Holy One, blessed be He, does not disdain the prayer of the multitude" refers only to tefillah be-zibbur, not to the prayer of groups of individuals, of any sex, which do not constitute a minyan. Little wonder, then, that there is no encouragement of women's prayer groups on the part of knowledgeable rabbis! Such encouragement would be tantamount to lifnei iver—advising a less advantageous mode of action when a parallel and much more advantageous course of conduct is readily available.
Many participants in women's minyanim speak and write movingly of the religious experience such participation brings them. Presumably, some may argue that the religious experience in which they share is sufficient reason to sacrifice the incontrovertible advantages of tefillah be-zibbur. That position is predicated upon a fundamental error—if not an error of Halakhah, then an error of hashkafah or religious perspective.
Let these comments not be understood as denigrating the value of religious experience. Kavanah (devotion) is certainly a form of religious experience and its value cannot be extolled too greatly. But Judaism recognizes a hierarchy of values and kavanah, deveikut, religious experience or "attachment," desirable and laudable as they may be, should never be permitted to supplant other values. The fulfillment of a mizvah in an optimal manner, albeit without extraordinary kavanah, is to be favored over less optimal fulfillment accompanied by fervent religious experience.
R. Chaim of Volozhin, Nefesh ha-Hayyim, sha'ar I, chapter 22, makes this point most eloquently. One who eats mazah on Pesaḥ, or lifts the four species on Sukkot but experiences absolutely nothing that can be described as uplifting or spiritually edifying has nonetheless fulfilled a divine command; his act has cosmic ramifications and he will receive great reward. Of course, kavanah would greatly enhance the already inestimable value of the mizvah, and should be the object of aspiration, but failure to achieve such kavanah is no cause for distress. On the other hand, eating mazah on Sukkot or lifting the four species on Pesaḥ, regardless of any attendant "religious experience," is entirely devoid of significance.
Kavanah and the most intense of religious experiences are essentially meaningless if the act itself is deficient in any way, even if only by virtue of inattention to one of the myriad details which constitute the sine qua non of the requisite fulfillment of the mizvah. Similarly, the enhancement of a mizvah in its objective performance takes precedence over intensification of subjective religious experience.3See R. Moses Feinstein, Iggerot Mosheh, Oraḥ Ḥayyim, III, no. 7. Assuredly, the guaranteed benefits of tefillah be-zibbur outweigh those of any possible subjective experience. This ranking of values is intrinsic to the value system upon which Halakhah is predicated; the choice of optimal performance of a mizvah over intensification of kavanah when confronted by a choice between the two is a substantive matter of Halakhah itself. It was against those who challenged this view that the Nefesh ha-Hayyim was written and against whom R. Chaim of Volozhin inveighed.
Even more distressing is the public reading of the Torah which is the major innovation of women's minyanim. One is touched by the emotional description of this experience and of how much it means to the participants. Yet, the obvious sincerity of the exponents is not matched by objective considerations.
Certainly, it is permissible for any person to read or to study from a Torah scroll at any time. Indeed, the original biblical rule was that the Written Law may be studied only from a written text, which by definition means a Sefer Torah written on parchment in the prescribed manner. Two thousand years ago that would have been the only permissible way of studying the words of the Torah. But rabbinic exegesis renders Psalms 119:126 as "It is time to act on behalf of God; thwart Thy Torah." This verse is understood as teaching that when it becomes impossible to transmit the Oral Law without committing it to writing or when it becomes impossible to teach the Written Law solely by means of a properly written scroll, other methods may be used. Hence, today there is absolutely no cogent reason for utilizing a Torah scroll rather than a printed text for purposes of Torah study. On the contrary, use of an unvocalized text can only lead to error and yield misinformation.
The sole reason for utilization of a Torah scroll in conjunction with communal services is the fulfillment of the rabbinic requirement which demands that such reading be from a properly written scroll. Although disputed by other authorities, Magen Avraham, Oraḥ Hayyim 282:6, cites Masekhet Soferim as ruling that women are required to attend the reading of the Torah. Nevertheless, such reading must be conducted in conjunction with a properly constituted (i.e., male) minyan. Women's prayer groups cannot fulfill that obligation even when a Torah scroll is utilized. In no way can the reading of the Torah in such a context be categorized as even a voluntary fulfillment of the rabbinic commandment. Since use of a Sefer Torah is halakhically meaningful only when it is used for purposes of fulfillment of the rabbinic commandment, the formal use of a Torah scroll by women who candidly acknowledge that they do not thereby fulfill the rabbinic requirement borders on the farcical.
In instituting Kri'at ha-Torah complete with aliyot (although without recitation of blessings) there is manifest a clear desire to establish a formal, innovative, liturgical ritual. That, in itself, is objectionable. Rambam, Hilkhot Melakhim, chapters 9 and 10, spells out in detail the obligations of non-Jews under the Noachide Code. They must abjure idolatry and accept the Seven Commandments of the Sons of Noah. But Rambam adds in 10:9, that, even as monotheists, they are not permitted to develop religious practices of their own: "ein maniḥin otan le-ḥadesh dat ve-la'asot mizvot le-azman—they are not permitted to create a religion and to make commandments for themselves."
This ruling, at first blush, is somewhat puzzling. After all, the people of whom Rambam speaks believe in the one God; the practices contemplated are not idolatrous in nature. The rituals described are certainly innovative but they appear to be entirely innocuous. There is no mention of an accompanying claim of divine mandate. Why should we interfere with harmless rituals which non-Jews perceive as meaningful religious experiences and from which they derive spiritual satisfaction? Rambam's statement is even more puzzling since the talmudic source for this ruling is far from unequivocal.
It appears that Rambam finds cause for concern precisely because the persons described are monotheists who have accepted so much of Jewish practice and teaching. Permitting such individuals to generate novel rituals and religious practices would lead to confusion and misapprehension with regard to divine law. It might rapidly be assumed that such commandments are indeed of divine origin and are binding upon Noachides. The concern is not with regard to the act per se; the act itself if indeed perfectly innocuous and no ostensible halakhic objection can be raised. The objection is that the practice acquires the characteristics and overtones of a divinely mandated ritual and as such itself becomes a ziyuf ha-Torah—a falsification of the mesorah, i.e., of the Law handed down from generation to generation.
It is clear that what Rambam forbids Noachides is prohibited to Jews as well. Jews, after all, are explicitly commanded, "You shall not add to the matter which I command you" (Deuteronomy 4:2). One hesitates to state that Torah reading and aliyot, at least as now practiced by women's prayer groups, fall within the category of the forbidden ritual innovations prescribed by Rambam in Hilkhot Melakhim. Nevertheless, it appears that such practices come dangerously close to being so.4There is yet another consideration that augurs against women’s prayer services which include the Reading of the Torah. Rema, Oraḥ Ḥayyim 88:1, records a difference of opinion with regard to whether it is proper for a woman to enter a synagogue during the time of her monthly menstrual period. Magen Avraham, Oraḥ Ḥayyim 88:2, and Taz, Oraḥ Ḥayyim 88:2, followed by Mishnah Berurah 88:7, indicate that it is our practice for women to attend services in the synagogue at such times but caution them not to gaze at the Torah scroll when it is lifted to be shown to the assemblage. Kaf ha-Ḥayyim, Oraḥ Ḥayyim 88:11, permits such women even to gaze upon the script of the Torah scroll.
Although none of these authorities distinguish between gazing upon a Sefer Torah and touching it, there are sources that indicate that a distinction must be drawn between mere gazing and touching. Apparently, it was the practice in some circles to place a Torah scroll in the hands of a woman experiencing severe difficulty in labor. Teshuvot Ḥinnukh Bet Yehudah, no. 71, decries this practice on the grounds that a woman in a state of ritual impurity should not touch the Sefer Torah and therefore advises that the Torah scroll be brought only to the door of the delivery room “that the merit of the Torah protect her” but that the scroll not be placed in her hands. It is clear that Teshuvot Ḥinnukh Bet Yehudah forbids such women to touch even the wooden handles to which the parchment scroll is attached. A similar position is recorded in the name of Sefer Torat Ḥannokh by R. Dov Ber Spitzer, “Seder Ḥinnukh Sefer Torah,” sec. 3, published in Toldot Kol Aryeh (New York, 5723). However, Shulḥan Arukh, Yoreh De‘ah 282:8, specifically permits a menstruating woman to touch a Torah scroll.
There is no substitute for the prayer of the community as a unified whole. As so eloquently stated by Ramban in his commentary on Exodus 13:16, "The purpose of … synagogues and the merit of communal prayer is that people have a place wherein they assemble and express gratitude to the Almighty … and proclaim publicly and say before him 'we are Your creatures!' " To this end Jews, men and women alike, join together in the synagogue in common and collective expression of worship and devotion.
Immersion of a Bride Lacking a Uterus
Jewish law requires that, subsequent to accepting a proposal of marriage, a woman regard herself as a niddah. Accordingly, even if she does not menstruate during the interim period, the bride must nevertheless perform the requisite examinations over a period of seven days and immerse herself in a mikveh. The Gemara, Niddah 66a, explains that the emotional reaction generated by acceptance of a marriage proposal may cause minute spotting which, because of its paucity, is not perceived either tactilely or visually. Jewish law also requires that a virgin be considered a niddah subsequent to her initial intercourse. Although only the flow of uterine blood causes a woman to become a niddah, rabbinic law requires that a virgin regard herself as a menstruant upon her initial act of intercourse lest confusion arise due to lack of awareness of the halakhic distinction between hymenal and uterine bleeding.
In a collection of articles, Kovez Ma'adanei Melekh, published by the Lubavitch Foundation of Great Britain in 5743 in honor of the eightieth birthday of the Lubavitcher Rebbe, Rabbi Shrage Feivish Schneebalg examines the question of whether a woman who lacks a uterus is required to undergo immersion in a mikveh. The uterus may be absent as a result of a congenital anomaly, as in the case presented for Rabbi Schneebalg's consideration, or, more frequently, as a result of a hysterectomy. In either event, it is physiologically impossible for a woman lacking a uterus to become a niddah since, by definition, only uterine bleeding causes a state of niddah. Thus, under such circumstances, there is no factual consideration upon which to base a fear of unperceived menstrual bleeding. To be sure, both post-menopausal and pre-menarcheal brides are required to wait the statutory seven-day period and to undergo immersion even though the likelihood of menstrual spotting is highly remote.5However, with regard to post-menopausal women, cf., the discussion of R. Yehudah Asad, Teshuvot Yehudah Ya‘aleh, I, no. 191. Nevertheless, the question which must be resolved is whether the rabbinic decree is blanket in nature and applies in all cases, including those in which there is no physiological possibility of the bride becoming a niddah, or whether it is limited to cases in which at least a remote possibility of intramenstrual spotting is present.
Teshuvot Imrei David, no. 125, rules that the seven-day waiting period and subsequent immersion in a mikveh is required even in the case of a bride who has no uterus. Imrei David's principal argument is based upon a statement of the Gemara, Ketubot 60b. Jewish law forbids a widow or divorcée to enter into a new marriage until a three-month period has elapsed following the termination of the first marriage. This statutory waiting period is required in order that there be no question with regard to the paternity of a future child in the event that the woman is found to be pregnant shortly after consummation of the second marriage. The Gemara, Ketubot 60b, declares that even a post-menopausal woman, a barren woman, a woman who experiences a miscarriage after the death of her husband or after her divorce, or a woman who "cannot give birth," i.e., a woman who lacks a uterus, is also required to wait the statutory three-month period. This decree is clearly universal in nature and applies to all women, including women who could not possibly become pregnant. Although the rationale upon which the decree is based does not apply in such situations, and hence there exists no compelling reason to require such women to wait three months, the rabbinic decree is nevertheless applicable because it admits no exception (lo pelug). Arguably, the same should be true with regard to the rabbinic decrees requiring prospective brides, and virgins subsequent to their first act of intercourse, to consider themselves as menstruants.
Rabbi Schneebalg, however, rebuts this argument, claiming that the rabbinic decree concerning the three-month waiting period cannot serve as a paradigm with regard to other rabbinic edicts. Rashi, Yevamot 42b, comments that the edict was explicitly made applicable to women who could not possibly bear children lest other women erroneously fail to observe the three-month waiting period. Hence, argues Rabbi Schneebalg, absent evidence of specific intent on the part of the Sages to include a woman lacking a uterus in other edicts, there is no basis for assuming that such decrees are universal in nature.
Some evidence that these edicts are not universal in nature, and hence are not designed to apply when there is no possibility of menstrual bleeding, may be adduced from the comments of R. Shlomoh Kluger, Mei Niddah, Kuntres Aharon 192:4. In discussing the status of a premenarcheal bride, Rabbi Shlomoh Kluger declares that, although there is no cogent reason to suspect possible menstrual bleeding, the pre-menarcheal bride must consider herself a niddah because young girls were not exempted from the provisions of the decree (lo pelug). R. Shlomoh Kluger, however, cites the opinion of R. Zalman Margulies who maintains that the decree is applicable to pre-menarcheal women because of the remote possibility, however unlikely, that they may indeed experience bleeding. Thus, R. Zalman Margulies quite evidently rejects the concept of lo pelug in this context. Even R. Shlomoh Kluger, who accepts the concept of lo pelug in this instance, might well maintain that the concept of lo pelug applies only to situations in which the concern is at least a logical possibility, but not in situations in which such legislation would be entirely devoid of cogency. Moreover, Taz, Oraḥ Hayyim 275:1 and Even ha-Ezer 119:12, asserts that the concept of lo pelug applies only to varying situations in which a given individual may find himself, i.e., a person to whom a rabbinic edict is applicable may be bound by that edict under all circumstances, but that the principle does not apply "from person to person," i.e., it does not apply to a person who does not at all come within the ambit of rabbinic intent. Taz maintains that a person to whom a particular rabbinic edict is at no time logically applicable is not at all subject to that legislation. Additional evidence for the validity of this thesis is advanced by R. Joseph Saul Nathanson, Sho'el u-Meshiv, Mahadura Kamma, I, no. 22.
R. Yitzchak Ya'akov Weisz, Teshuvot Minḥat Yizḥak, I, no. 125, sec. 7, adduces evidence supporting the view that even a bride lacking a uterus must undergo immersion in a mikveh. Genesis 29:31 describes Rachel as an "akarah." Rashi, Yevamot 42b and Sotah 25b, states that the term "akarah" does not simply mean "barren" but is derived from the Hebrew verb "akor" meaning "to uproot" or "to pluck out" and is used to describe a woman who is sterile because she lacks a uterus. Accordingly, a miracle was necessary in order to effect an anatomical change so that Rachel might conceive. Yet, Arukh ha-Shulḥan, Yoreh De'ah 192:3, states that Laban's motive in directing Jacob to wait a week following his marriage to Leah before marrying Rachel (Genesis 29:27) was a concern for fulfilling the halakhic requirement that a bride deem herself to be a niddah and wait the statutory seven-day period before immersing herself in a mikveh (and not because of the reason given by the Palestinian Talmud, Mo'ed Katan 1:7, cited by Tosafot, Mo'ed Katan 8b, to the effect that "one should not mingle one celebration with another celebration" and hence if one sister marries, the second sister should not marry until the week-long nuptial celebrations of the first sister have been completed). Subsequent to Laban's duplicity in substituting Leah in place of Rachel, a new agreement was reached between Laban and Jacob for an additional seven years of labor in return for the hand of Rachel in marriage. The negotiation of that agreement was tantamount to a new proposal of marriage which again required a waiting period of seven days. However, since Rachel lacked a uterus and hence it would have been impossible for her to become a niddah, this concern would not have been cogent unless the rabbinic edict applies to all women without exception. Minḥat Yizḥak, however, rejects this argument and states that Rachel may have undergone a partial hysterectomy which left a portion of her uterus intact and, accordingly, she might yet have been capable of experiencing menstruation. Rabbi Schneebalg notes that Scripture describes Rachel as an akarah only after it reports her marriage to Jacob. Failure to disclose Rachel's barrenness may well have been part of Laban's duplicity. Hence, Jacob may have been unaware of Rachel's condition prior to their marriage and, therefore, may have erroneously insisted upon the seven-day waiting period.
In a more recent volume, Teshuvot Minḥat Yizḥak, VIII, no. 93, Rabbi Weisz affirms his earlier position that a bride who has undergone a hysterectomy need not immerse herself in a mikveh, but cautions that it is necessary to determine that the entire uterus has been removed.6See R. Shlomoh Zalman Auerbach’s treatment of a related topic in No‘am, VII (5724), 161-62. Although Rabbi Auerbach does not explicitly refer to the question of lo pelug, his omission of such discussion serves to indicate that, in his opinion, a bride is not required to immerse herself in a mikveh when it is known with certainty that she has not experienced a discharge of blood which would cause her to become a niddah.
Nevertheless, R. Judah Leib Zirelson, Ma'arkhei Lev, no. 44, rules that a bride who has had a hysterectomy must undergo immersion in a mikveh because of the principle of lo pelug. Ma'arkhei Lev incongruously adds that even subsequent to a hysterectomy there exists the possibility of menstrual bleeding from tissues surrounding the uterus. However, as Rabbi Schneebalg points out, Sifra, Parshat Mezor'a, chapter six, 4:2, followed by Rambam, Hilkhot Issurei Bi'ah 5:5, and Shulḥan Arukh, Yoreh De'ah 183:1, declare that only uterine blood generates a state of niddah. Accordingly, R. Joseph Engel, Teshuvot Maharash, VII, no. 12, and R. Aaron Walkin, Teshuvot Zekan Aharon, II, no. 3, rule that a woman who has undergone a hysterectomy cannot become a niddah.
Rabbi Schneebalg concludes his discussion by citing Sefer Hasidim, no. 389, whose phraseology indicates that immersion in a mikveh is required even for a bride who has definitely not experienced any discharge of blood. In light of these conflicting opinions, Rabbi Schneebalg advises that a bride who lacks a uterus should immerse herself in a mikveh without pronouncing the benediction.