Tefillin on the First Day After a Night Burial
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Question
What is the ruling for someone whose relative was buried at night? Should they put on tefillin the next day?
Answer
He does not put on tefillin the next day, as the main mourning is on the first day of consolation.
Source
Mishna Berura, Siman 38, S"K 16: "Even on the day of burial, which is not the day of death, since it is the first day of mourning and consolation, therefore, even if buried at night, tefillin are not put on during the day," as it does not consider the opinion of the Maharitz that only in Torah-mandated mourning is one exempt.
And it seems that even if consolation began at night, the main mourning is on the first day, since after the burial at night there is a meal of consolation, and the main consolation is the next day, hence tefillin are not put on.