Birkot Hatorah after a nap?

The Shulhan Aruch (O.H. 47:10) writes that a settled sleep on one’s bed during the day is considered an interruption with regards to Birkot Hatorah and that one would have to repeat them after sleeping. Some, however, maintain that it is not an interruption and the Shulhan Aruch mentions that this is the common custom.  The Ra’ah (Berachot 11b) explains that one reason that it is not considered an interruption is because for the general population the daytime is not a time for sleeping, even if for an individual it may be so. Therefore because of this and because of the general principle of Safek Berachot Lehakel, one who wakes up from a daytime nap would not repeat Birkot Hatorah.

One practical implication of this Halacha involves taking a short nap at night, such as if one naps after the Shabbat night meal and then wakes up to learn. Rabbi Ben Zion Abba Shaul (Or Lezion, vol. II, ch. 4, § 6) says that if one napped in one’s bed for at least thirty minutes, one would be required to repeat Birkot Hatorah upon waking up. Rabbi Ovadia Yosef (Yabia Omer, vol. VIII, § 5:5) says that if one napped for just a few minutes, and even if one remained in one’s clothing, one would need to repeat the blessings. Furthermore, if one’s nap began in the daytime and extended even a few minutes into the night, one would be required to repeat Birkot Hatorah. It has been said of Rabbi Shlomo Zalman Auerbach that he would nap after the Shabbat night meal with his clothes and for this reason he would not repeat Birkot Hatorah. When it comes to staying up all night, the Magen Avraham posits that the Shulhan Aruch (ibid.) seems to imply that one would not recite Birkot Hatorah and would rely on the Birkot Hatorah that were recited the previous day. Rabbi Ben Zion Abba Shaul  (ibid., vol. III, ch. 18) says that there are those who write that according to Kabbalah one would be required to recite Birkot Hatorah at dawn. Nevertheless, the Moroccan custom is based on the Magen Avraham‘s inference on the Shulhan Aruch which implies that when one stays up all night, such as on Shavuot, one should rely on the blessings of someone who and will have one in mind. Even though the other Birkot Hashahar can be recited even if one stayed up all night, the custom is that since one will hear Birkot Hatorah from someone who slept, then one will have that person recite all the blessings on one’s behalf.  It should be noted that if one stays up all night, one does not recite “Al Netilat Yadayim”.

Summary: One does not repeat Birkot Hatorah after a daytime nap. One should repeat Birkot Hatorah if one naps at night and wakes up to learn. If one stays up all night, one should have someone who slept recite all the Birkot Hashahar and Birkot Hatorah on one’s behalf.