“Question: Does tevilas keilim need kavono? I.e. if utensils were immersed in a kosher mikva without intention to perform the mitzvah of tevilas keilim, is this tevilah valid?
Discussion: The requirement of kavono regarding tevilas keilim is found in several Rishonim in the context of tevilas keilim being performed by a minor or non-Jew:
• The Beis Yosef (Yoreh De’ah Siman 120 se’if 14) quotes the Terumas Hadeshen (Siman 257) who discusses if a minor may perform tevilas keilim. The Terumas Hadeshen writes that although a minor has no halachic credibility, if he was tovel utensils under the supervision of an adult, the tevila is valid. And even according to the opinions that require kavono for tevilas niddah; over here it may be possible to teach the child to have the necessary kavono, or tevilas keilim may not require kovono at all.
• The Beis Yosef (ibid se’if 15) quotes the Teshuvos Meyuchosos (Siman 151) who was asked about a non-Jew performing tevilas keilim, and he answered that it appears to be permissible.
• The Beis Yosef continues and quotes the Teshuvos Rashbo (volume 3, #255) who also discusses a non-Jew performing tevilas keilim. Within his discussion he states that chullin does not require kavono, and also that tevilas keilim performed by a non-Jew cannot be worse than the situation where a niddah was tovel without intent [i.e. she immersed because she wanted to cool down, and although there was no intention her tevila is valid]. The conclusion of the Rashbo is that if tevilas keilim was performed by a non-Jew the tevila is valid.
The Bach (Yoreh De’ah Siman 120) discusses a situation where keilim purchased from a non-Jew fell into a mikva accidentally [without intention of tevila] and writes that since the Remo (Yoreh De’ah Siman 198 se’if 48) rules like the stringent opinions regarding a niddah who was tovel without kavono [and requires her to repeat the tevila with kavono], we should similarly rule that these keilim ideally require tevila again with kavono.
• The Remo (Yoreh De’ah Siman 120 se’if 14) rules in line with the aforementioned Terumas Hadeshen, that if a minor was tovel utensils under the supervision of an adult, the tevila is valid.
The Taz (s.k. 16) infers from the Remo that there is no requirement to teach the minor to be mechaven (as was suggested by the Terumas Hadeshen); i.e. tevilas keilim does not require kavono.
• The Shulchan Aruch (Yoreh De’ah Siman 120 se’if 15) rules that if a non-Jew was tovel utensils, the tevila is valid.
The Shach (s.k. 28) infers from the Shulchan Aruch that if keilim accidentally fall into a mikva the tevila is valid and does not need to be repeated (unlike the Bach who ruled stringently).
[The Vilna Gaon (Bi’ur Hagro s.k. 38) appears to infer from the wording of the Shulchan Aruch [who discusses tevilas keilim performed by a non-Jew only ex post facto and does not write clearly that this is permitted l’chatchilo] that ideally if tevilas keilim was performed by a non-Jew, or if a keli fell into a mikva accidentally, it is preferable to tovel the keli again – with kavono.]
Conclusion: Tevilas keilim does not require kavono; therefore if keilim fell into a mikva accidentally the tevila is valid and does not need to be repeated.
[Although both the Bach and (ostensibly) the Vilna Gaon do rule that one should repeat the tevila, this is a minority view. The Shach and Taz clearly rule that there is no requirement of kavono and the basic reading of Shulchan Aruch and Remo clearly implies the same.]
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