Prayer while riding in public transportation

What should one do when he is riding a bus or a train, or flying in an airplane, and if he stands up to pray, he won’t be able properly to concentrate on his prayer?

He should pray while sitting down, since, if he prays while standing, he won’t be able to concentrate (as is often the case in a crowded bus, on a winding road, or while riding in a private car). At any rate, when he reaches the place in a prayer where he has to bow down, he should make an effort to stand up and bow down; if it’s impossible to stand up, he should bow down while seated. The same applies to the obligation to take three steps back at the end of prayer. If he's in a place where it’s possible for him to stand up (such as on a bus), he should stand up and take three steps back. And if he’s praying while sitting down, he should keep his feet together just as he does when praying while standing.

The Talmud (Brachot 30a) states: “if he was riding on a donkey, and the time came for him to pray, if he has someone to hold the donkey, he should dismount and pray; if he doesn’t [have anyone to help him with the donkey], he should pray while sitting in his place. Rebi says: ’either way, he should pray while sitting in his place, since his thoughts are in disarray’. Rova – according to some opinions it was Rabbi Yehoshua ben Levi – states that the law is established in accordance with Rebi.” And indeed, the law follows Rebi’s opinion, that is, either way one should pray while sitting down. This is the ruling of the Rambam (Laws of Prayer, chapter 5, section 2) and the Shulchan Oruch (section Orach Chaim, ch. 94, §4).

The Talmud continues: “one who woke up early to sit in a carriage or in a boat should pray”. There are two ways to understand this quote. One way is that someone who is riding in a carriage doesn’t have to alight from it to pray, but he does have to stand up. Thus, the law that applies to someone riding in a carriage is different from the law that applies to someone riding a donkey, for the latter is unable to stand up for prayer. The other way to understand this Talmudic statement is that one can pray in a carriage while sitting down, since the Sages did not burden him with the obligation to stand up for prayer while riding.

At first glance, we could choose one understanding of the above passage and reject the other, based on the statement of the Meiri (in commentary to the tractate Brachos, ibid.). Meiri writes that even one who is praying while riding an animal still has to make an effort to stand up for prayer, if it’s possible. The only lenience that the Sages granted to a traveler is that he doesn’t have to dismount the animal he’s riding in order to pray, even in a situation where it is possible. What can be derived from that is that someone who is riding in a carriage or a wagon should certainly stand up for prayer, if it’s at all possible.

However, there is a disagreement between the codifiers as to this question. This is what the Shulchan Oruch (ibid.) says regarding one who is riding in a wagon or sailing on a boat: “if he can stand up, he should stand up; if he cannot stand up, he should pray while sitting in place.” It’s clear that the Shulchan Oruch is following the Meiri’s opinion, according to which, the one who rides a carriage or sails in a boat is not always allowed to pray while sitting. I he is able to stand up, he should stand up. (However, as regards someone who is riding on a donkey, the Shulchan Oruch differs with the Meiri, and states that it doesn’t matter if he can raise up, or not, [he can always pray while sitting]. The commentaries explain that the law that applies to the one riding an animal is more lenient because it’s more difficult to stand up while riding astride an animal that while riding in a wagon.)

On the other hand, the Arbaa Turim (ibid.) writes thus: “and someone who is in a carriage or in a boat prays while sitting as well”. The fact that the Arbaa Turim does not mention that someone who is able to stand, has to stand up to pray, implies that, according to his opinion, one who rides in a carriage may pray while sitting down. Someone who is riding in a wagon or sailing in a boat is not obligated to stand up to pray. It can be assumed that the ruling of the Arbaa Turim is based on the law pertaining to the donkey rider. Just like someone riding a donkey has no obligation either to dismount nor to stand up while astride the animal, so too, someone riding in a wagon is obligated neither to alight from it, nor to stand up while praying inside it.

However, the practical law follows the decision of the Shulchan Oruch and the laws that are derived from the Biur Halachah commentary (ibid.).