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The few authorities who do permit ten women to use the zimmun be-Shem formulation explain that the necessity for ten in this case is unique and cannot be compared to other instances requiring minyan.

Only Rabbeinu Simcha among these authorities mentions the possibility of one woman joining with nine men to form a minyan for prayer.

His inclusion in minyan is thus subject of Talmudic dispute.

Based on the Talmudic passage in Berachot, Rabbeinu Tam states that a minor can act as the tenth person and according to the Baal Ha-Maor, up to four minors would be permitted.

Jerusalem Talmud The Jerusalem Talmud (Megillah 4:4) offers two sources for the requirement, also using a Since the term "congregation" in the later verse refers to the ten spies, so too in the former verse: "You shall be holy" refers to a "congregation" of ten.

The second source is based on the term "children of Israel" which appears in the following two verses: Just as the "children of Israel" in the later verse refers to the ten sons of Jacob who descended to Egypt to obtain food during the famine, so too the former verse refers to sanctification among the “children of Israel” in the presence of ten.

The Talmud itself does not directly address the question of whether women may count as part of a minyan for devarim shebkdusha.

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Although the issue of whether women are permitted to make up a minyan has been noted in early works, the matter has only come to the fore in the past few decades, a reaction to an enhanced role of women in modern society and to the demand for their inclusion in all areas of religious life.

" is referring to the ten spies, a congregation comprising Jewish adult males.

It is understood from this that a minyan must likewise comprise ten Jewish adult males.

Some authorities deduce who may constitute a minyan by drawing on the verses which are brought as the basis for minyan and their implication.

For example, the verse, "How long shall I bear with this evil congregation which murmur against me?