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Chapter 2

Halakha and the Custom of the Merchants

2.1 The Babylonian Geonim and the Custom of the Merchants

Maimonides’ predecessors, the Babylonian Geonim, were quick to recognize the transformation in Jewish economic life that followed the Islamic conquest and, in particular, the role that merchant custom—some of it inconsistent with Talmudic halakha—played in Jewish business affairs.¹ With unabashed transparency, they introduced modifications in Talmudic law, without having to call upon the Talmudic principle of dina de-malkhuta dina (“the law of the state is law”).²

A prime example is the order of payment known as the suftaja. Muslim long-distance traders widely employed this fiscal instrument, and Jews themselves may have begun using it as early as the mid-eighth century.³ It is abundantly attested in merchant letters from the Geniza for the eleventh to early thirteenth centuries. In a typical example, person A needed to transfer money to a distant addressee, person C. To avoid the risk of loss of specie, through brigandage, or shipwreck, or other cause, he would send a suftaja in that amount with person B to the addressee, who would cash the suftaja through a local person holding money on behalf of person A. The avoidance of loss due to the danger of transporting specie was considered a benefit to person A, hence a veiled form of interest. For that reason, some Islamic legists objected to the device, and it was problematic for the Geonim as well.⁴

Queried about the halakhic permissibility of the suftaja,5 an unnamed Gaon authorized its use, even though the Talmud (Bava Qamma 104b) ruled against employing a similar device, called diyoqne (diyuqne), a word taken from the Greek and betraying its origins in the pre-Islamic, Greco-Roman period.⁶ The responsum is significant, not only because it illustrates realistic rabbinic adjustment to economic change but also for its specific use of the term “custom (or law) of the merchants.” “Our halakha [fiqh] does not support the sending of a suftaja, as our rabbis said: ‘One may not send money with a diyoqne, even if witnesses have signed it.’ However, when we saw that people use it in doing business with one another, we began admitting it in court, lest trade among people cease. We sanction it, no more and no less, in accordance with the ‘custom (or law) of the merchants’ [ḥukm al-tujjār]. Such is the law and nothing should be altered in it.”⁷ The occurrence of the concept ḥukm al-tujjār in a Gaonic legal opinion—in a Geniza court record from 1141, it is referred to as al-‘āda bi-Miṣr bayn al-tujjār fī l-sharika, “the custom in Fustat among the merchants concerning partnership”⁸—sanctioning a practice frowned upon by the Talmud but essential in the monetized economy of the Islamic world, is telling. It is reminiscent of the Latin term lex mercatoria, “law merchant,” in medieval Europe, used to describe a body of marketplace customs peculiar to and shared by merchants, and which A. L. Udovitch long ago suggested had a counterpart in what he called “the ‘law merchant’ of the medieval Islamic world.”⁹ Leaving aside the contentious debate about the merchants’ law in Europe—whether such a corpus of laws really existed; and, if it did, where it first appeared; whether these customs originated with merchants or with legislation by the “state”; whether they represented the common, “transnational” practice of merchants everywhere; and how these customs were transplanted from place to place¹⁰—it is clear that the Geonim were aware of and concerned about merchant customs that contradicted Talmudic halakha. Their solution was to let custom override the halakha¹¹ and sanction the suftaja, as they said, “lest trade among people cease.” Saadya Gaon (d. 942) expressed the Gaonic rationale with similar resignation: “In all transactions of the merchants, diyoqna’ot [plural of diyoqne] are not acceptable according to strict law, but the merchants have disregarded [the prohibition] in order to facilitate their transactions.”¹² This comment and the remark “We saw that people use it in doing business with one another,” in the responsum on the suftaja indicate that Jewish merchants followed well-established customs of their economic class, adhering to norms that were not always consistent with the Talmudic legal system but that had been inscribed in Islamic law during its formative period. The Geonim certainly knew that if they did not accommodate the use of the suftaja, in any dispute concerning this device Jewish merchants would simply resort to Islamic courts, where the commercial instrument was recognized.¹³ Gaonic sanction of the suftaja meant that Jewish merchants could bring litigations involving this financial device before the Jewish beit din, rather than seeking resolution in the court of the Muslim judge. In the wake of the Geonim, the suftaja gained codified status as a valid “custom followed by the merchants” in the Halakhot of R. Isaac Alfasi and, later on, in Maimonides’ own Code, in the name of “my teachers” in al-Andalus.¹⁴

Other Gaonic adjustments reflect their awareness of the new mercantile economy as well. In a taqqana from the second half of the eighth century, they ruled that widows claiming the money promised them in their marriage contract and payable upon the death of their husbands, as well as general creditors claiming repayment of a debt, could collect what was owed them from the deceased husband’s movable property. The Talmud stipulated that they could place a lien only on his real property. A responsum attributed to an early ninth-century Gaon explains the reason for the taqqana: “Here [in Babylonia], most people [i.e., Jews] do not own land.”¹⁵ The new rule had the dual purpose of protecting women’s postmarital livelihood and keeping credit flowing in an economy that very much depended on credit in the purchase and sale of commodities.

In conforming Jewish law to the needs of the Islamicate marketplace, the Geonim faced a greater challenge than their Muslim counterparts. The formative period of Islamic law coincided with the Islamicate commercial revolution. In a seminal article, “The Rise of the Near Eastern Bourgeoisie in Early Islamic Times,” S. D. Goitein showed that most of the early Muslim jurists were themselves merchants, or at least au courant with merchant custom.¹⁶ Joseph Schacht had already shown that customary commercial law of pre-Islamic Mecca, echoed in commercial terms in the Qur’ān, entered Islamic law in its formative period.¹⁷ These customs, like the suftaja, were therefore absorbed into Islamic law as early as the eighth century. The most flexible and “liberal” of the law schools (madhhabs) in this respect, the Ḥanafīs, named after their founder, Abū Ḥanifa (d. 767), and, to a lesser extent, other legal schools incorporated these practices into Islamic law as it took shape.¹⁸

In contrast, the formative period of Jewish law had long passed when the Islamicate commercial revolution arrived. The Geonim had a huge corpus of halakha from the pre-Islamic, Talmudic period to contend with, and this corpus served an agrarian society, not a highly commercialized, monetized society in which long-distance trade and credit figured prominently. Like the examples cited above, they accommodated these transformations through their responsa, through taqqanot (though they seem rarely to have resorted to this halakhic tool), through what they called “the custom of the yeshiva,”¹⁹ and through rulings incorporated into mini-codes, many of which deal with commercial law.

2.2 “Custom Overrides the Halakha” and Qinyan Siṭumta

The Geonim had a juristic tool at their disposal that they could deploy when faced with discrepancies between Talmudic law and contemporary merchant practice recognized by Islamic law. This was represented by a rabbinic maxim, minhag mevaṭṭel halakha, “custom overrides the halakha,” analogous to an Islamic legal maxim, al-‘āda muḥakkima, “custom is legally authoritative.”²⁰ The Jewish maxim appears in the Palestinian Talmud.²¹

The Talmudic precedent for this concession to daily economic affairs occurs in connection with transfer of ownership (Heb., qinyan). Recognizing the necessity for flexibility when buying and selling, the Talmud validates a procedure called siṭumta (meaning “a seal”), which, if it conformed with local custom, could substitute for one of the methods of acquisition dictated by the Talmud, such as physically pulling the object (meshikha) or lifting it up (hagbaha). The example given by the Talmud is wine. The medieval commentator Rashi, thinking of the importance of wine as a commodity in his own time and place in eleventh-century France, explains the notion as follows. When a retailer purchases barrels of wine for his shop from a winemaker, he does not take all of them at once but leaves some in the seller’s wine cellar to be claimed later, as needed. He marks the kegs with a siṭumta to identify them as his own. This procedure signifies proof of purchase and substitutes for “pulling” the object.²² As summed up by R. Solomon b. Adret (Rashba; thirteenth-century Spain), “we learn from this that custom overrides the halakha [minhag mevaṭṭel halakha] as well as in any similar matter. In all monetary matters, one may buy and sell in accordance with custom. Therefore, one may complete a purchase in whatever way it is customary for merchants to do so.”²³ Rashba’s rule echoes, further, an axiom of economic history: mercantile custom typically evolves out of the needs of the marketplace, in contexts connected with trade, rather than in schools of law.²⁴

2.3 Trade and the “Custom of the Mariners”

The importance of custom in Jewish economic life is attested in the Talmud in a concession to practice in the surrounding society that was to prove essential for long-distance trade during the Islamic period. I refer to what the rabbis call minhag ha-sappanim, the “custom of the mariners.”

Classical rabbinic literature, it has been observed, contains a paucity of nautical terms.²⁵ While the Mishna, the Tosefta, and the Talmuds contain occasional discussions of legal issues relating to sea travel, which some have argued represent traces of an indigenous Jewish “admiralty law,”²⁶ these scattered fragments do not bespeak a widespread phenomenon of long-distance trade by ship that would have required detailed halakhic regulation.²⁷ Stories in rabbinic texts about arriving in or traveling to medinat ha-yam, literally, “the land of/by the sea,” apparently originally meant not across the high seas but rather the Mediterranean coastal district of Palestine. Only later did this term assume the meaning of beyond the shores of the Land of Israel, namely, the lands of the Hellenistic diaspora at the eastern end of the Mediterranean.²⁸

When Jews did travel by ship, for study, to visit family, to find a wife, or occasionally on business, they followed the custom of the mariners, a set of practices devised and put into practice by seafaring people in the society in which Jews lived. Classical rabbinic law mentions this concept once, in the Talmudic tractate Bava Qamma 116b, with a parallel in the Tosefta. Notably, the case regarding sea travel is preceded by an example concerning overland transport by donkey caravan, where the concept of the “custom of the mariners” is replaced by the “custom of the ass-drivers.”

[1] Our Rabbis taught: If a caravan traveling in the desert was attacked by armed men threatening to plunder it [le-ṭorfah], they reckon [the contribution to be paid by each merchant to buy them off] according to the monetary value [of the goods of each merchant] but not according to the number of souls. But if they hired a guide to go ahead of them, they also reckon [compensation for the loss] according to the number of souls [in the caravan]. They must not deviate from the custom of the ass-drivers.… [2] Our Rabbis taught: If a ship traveling on the sea was hit by a storm threatening to sink it, so that they jettisoned some of the cargo [lit., “lightened its weight”], they reckon [indemnification for the loss] according to the weight of the cargo and not according to its monetary value. They must not deviate from the custom of the mariners.²⁹

The case in the Talmud recalls the rules of jettison and general average (equalized division among all merchants of responsibility for overall loss through jettison) in the ancient Roman law of the sea. This law was summarized later in Justinian’s Digest (sixth century) and elaborated subsequently in the Nomos Rhodion Nautikos (Rhodian Sea Law), thought to have been compiled between 600 and 800 C.E.³⁰ Boaz Cohen, the eminent scholar of comparative Jewish and Roman law, pointed to the similarity between the maritime law of salvage in the classical rabbinic sources and in Justinian’s Digest.³¹

In an important book comparing the Rhodian Sea Law with Islamic maritime law as reflected in Islamic fatwās and in the Arabic Kitāb akriyat al-sufūn wa,’l-nizā‘ bayna ahlihā (“Treatise Concerning the Leasing of Ships and the Claims Between [Contracting] Parties”), Hassan Khalilieh argues that these rules from the late Roman Empire were mediated into Islam by local, Greek-speaking non-Muslims and “Islamicized” to conform with Qur’ānic and prophetic principles.³² An example from Islamic maritime law would be the requirement that all shippers share in losses incurred when jettisoning cargo.³³

The regulation in the Talmud that apportionment of loss among the travelers should be determined by weight and not by the monetary value of the jettisoned items addresses one of the basic issues in ancient and medieval legal discussions of jettison, though in Justinian’s Digest and in virtually all medieval laws of jettison, the preference is for calculation by monetary value rather than by weight. Logically, weight was the primary consideration at the moment of jettisoning, though monetary value took center stage when merchants came to settle accounts later on.³⁴ In a parallel halakha, the Palestinian Talmud (Bava Meṣi‘a 6:4, Venice edition 11a) stipulates that apportionment of loss is by both weight and value, evidently reflecting the dual consideration that operated in cases of jettison.³⁵

The great diversity of rulings on jettison in ancient and medieval legal sources led Olivia Constable to surmise that “they must have reflected local practice and a common understanding of the basic principles of general average.” She illustrates this with diverse opinions in Islamic maritime laws about how to assign value to goods cast overboard.³⁶ The Talmudic statement “they must not deviate from the custom of the mariners,” supports her assumption that customs varied from place to place and shows that, in the absence of halakhot covering maritime law, the rabbis of the Talmud and, in this respect, Maimonides as well, recognized and enforced customary practice current in the surrounding society.³⁷ This precedent later informed the halakhic “policy” recognizing non-Jewish shipboard law when Jewish merchants traveled with their goods on ships owned by non-Jews, usually Muslims.³⁸

With the coming of Islam, many new commercial customs came to the fore that required juristic attention and accommodation in the halakha. This process was begun relatively early by the Geonim, chiefly by granting commercial customs practiced in the Islamicate marketplace the force of law, exemplified by their legalization of the suftaja.³⁹ Maimonides, who inherited the legal tradition of the Geonim and of his teachers in al-Andalus, expanded on the foundation laid by his predecessors, carrying their work of responding to the realities of the marketplace to a new level of attainment through the process of codification in the Mishneh Torah.

2.4 The Custom of the Merchants in Maimonides’ Code

Maimonides is likely to have been exposed to the custom of the merchants already during his youth, growing up in the commercial milieu of Muslim Spain and North Africa.⁴⁰ Upon his arrival in Egypt, as we know from Ibn al-Qifṭī, he was engaged in trade in precious gems.⁴¹ He was intimately familiar with merchant custom from his India trader brother and from the legal queries about merchant activities that he regularly received. It should come as no surprise, therefore, to find Maimonides acknowledging and giving normative standing to the custom of the merchants in his Code.

A key text marking the place of merchant custom in the Code is found in the lead halakha of chapter 5 of Hilkhot sheluḥin ve-shutafim (Laws of Agents and Partners). Notably, however, the codifier does not use the phrase “custom of the merchants.” Here, as elsewhere in the Code, for the custom of the merchants, he uses the Hebrew phrase minhag ha-medina, literally, “custom of the land” or “local custom,” a locution that occurs in the Mishna, the Tosefta, and the Talmuds in relation to both ritual and civil law. He might have employed a neologism, minhag ha-soḥarim, translating the Gaonic term ḥukm al-tujjār and parallel to his own use of minhag ha-sappanim. His choice of the old, Tannaitic Hebrew expression minhag ha-medina suggests that he wished to anchor the custom of the merchants in his own time to the ancient halakha.

If a person forms a partnership with another without indicating stipulations [bi-stam], he may not deviate from local custom [minhag ha-medina] as regards that kind of merchandise. Nor may he travel to another place, or form a partnership with others with the same kind of merchandise, or deposit it with others as a bailment, or trade in any other merchandise. He shall not sell on credit except that which it is always the custom to sell on credit—unless [both partners] stipulated this at the outset or [the itinerant partner] acted with the other’s knowledge. If he deviates and acts without the other’s knowledge and afterwards tells him “I did such-and-such” and [the stationary partner] consents to this, then the former is not held liable. None of these matters requires ratification by qinyan. Oral agreement alone is sufficient.

The standard commentators could find no precise source for this halakha in its entirety in a classical rabbinic text. For the statement “or trade in any other merchandise,” R. Joseph Caro (d. 1575 in Safed, Palestine) in his Kesef Mishneh, one of the major commentaries on Maimonides’ Code, cites a baraita in the Tosefta (Bava Meṣi‘a 4:12 in the Lieberman edition), which is also cited by R. Isaac Alfasi in his epitome of the Talmudic tractate Bava Meṣi‘a. The core text in the Mishna (Bava Meṣi‘a 4:5) concerns a person hired to tend a shop. If he is a craftsman, the Tosefta adds, he should not practice his craft while on duty, lest he fail to pay attention to the customers. In Beit Yosef, Caro’s commentary on another great work of codification, the Tur, by Jacob b. Asher (d. 1340 in Toledo, Spain) (Hoshen Mishpaṭ 176:10), the author speculates that Maimonides is analogizing from that case to a partner, who should devote all his attention to the partnership at hand, lest he be distracted by other business. In fact, as we know from the Geniza letters, merchants dealt in a myriad of different types of merchandise, often merchandise belonging to partnerships that they held at one and the same time with different merchants, and it was easy to lose track.

The topic sentence, “If a person forms a partnership with another without indicating stipulations, he may not deviate from local custom [minhag ha-medina, lit., “custom of the city or region”] as regards that kind of merchandise,” warrants special attention. It calls to mind a principle expressed in Islamic jurisprudence with respect to hire: “Whatever is not stipulated explicitly [ghayra mashrūṭ] in the contract is treated in accordance with the custom of each city.”⁴²

The phrase “local custom” (minhag ha-medina) is, indeed, key to contextualizing the halakha in question. It reflects aspects of everyday commercial practice in the Islamic world known to us from the Geniza and other Jewish sources from the Islamic period, particularly business arrangements concluded without drawing up formal, written contracts, which will be discussed in detail in chapters to come. The final sentence in the halakha makes this explicit: “Oral agreement alone is sufficient.”

The phrase “[n]or may he travel to another place … unless [both partners] stipulated this at the outset or [the partner in question] acted with the other’s knowledge” reflects the concern expressed in many Geniza letters or contracts and in a responsum of R. Isaac Alfasi that partners or agents keep to their prescribed itinerary, and it resonates with geographical restrictions that could be imposed upon an active party in an Islamic commenda, a type of business collaboration that we will discuss in Chapter 5.⁴³ Violation of an agreement about trading destinations, along with infringement of other conditions, often ended up in court or on the desk of a jurisconsult like Maimonides. One of his responsa, for instance, describes a dispute that arose in a commenda, called by its Arabic name, muḍāraba, in the query. The active merchant was supposed to proceed to a certain city, sell the merchandise belonging to the stationary investor, take his portion of the profit, and turn the capital sum plus the investor’s earnings over to a specified person in that place. However, as is typical of so many informal arrangements between Geniza merchants, the traveling party and the investor had not recorded the stipulations in a contract; rather, they had agreed about this orally in front of the active partner’s two brothers, who happened to be his designated heirs.

The traveling merchant sold the investor’s merchandise but failed to deliver the latter’s money as directed. Instead, be purchased other goods with the proceeds and departed for another destination by sea. When the ship on which he was traveling capsized, he lost his life, and only a portion of the goods that he was transporting could be salvaged. The investor demanded that the man’s heirs pay him the entire original capital and all his profits because their brother had violated the conditions agreed to in their presence. Because there was no written contract, the case came before the Jewish court and ultimately was submitted to Maimonides for his opinion. He ruled that the truth about the agreed conditions could be ascertained only by the heirs taking an oath, the typical method of resolving disputes in both the Jewish and the Islamic courts in the absence of third-party testimony.⁴⁴

The provision in halakha 5:1 about credit and the custom of the merchants reflects problems that could, and often did, arise when partners failed to stipulate whether merchandise could be sold on credit. Islamic schools of law discuss and disagree about whether a partnership contract needs to specifically stipulate permission to trade on credit.⁴⁵ Gaonic opinions were divided on the matter as well, but the power of merchant custom driving the commercial economy, in which credit was an essential tool, overcame compunctions in the Jewish, as it did in the Islamic, case.⁴⁶

A responsum of the Babylonian Gaon Samuel b. Ḥofni (d. 1013) relates the story of a merchant-traveler who engaged in credit transactions. His action was challenged by the stationary partner, who claimed that he had not granted the man permission to extend credit to customers. The Gaon supported the active partner’s actions because the man was putting his own money in jeopardy as much as that of his partner and because the stationary partner had not formally stipulated in advance that the other person should not sell on credit. The former, moreover, could not invoke the Talmudic rule expressed in the contract clause, “I sent you for my benefit, not to my detriment,” because the active party was neither an agent nor a paid employee but rather a partner.⁴⁷

Sale on credit was always potentially problematic because of the effort needed to collect what was due. Understandably, many stationary investors instructed their active partners to avoid such transactions. An example from the Geniza is a partnership contract among four investors in which the single, active partner agreed explicitly not to sell on the basis of “deferred payment” (ṣabr), meaning at a higher price, a way of circumventing the prohibition against taking interest among Jewish coreligionists.⁴⁸

Maimonides’ ruling on credit transactions in halakha 5:1 acquires particular significance in light of the extensive use of credit in the world of the mobile Geniza traders. In a situation where instructions about credit are not specified, Maimonides rules that everything depends on local merchant custom. The itinerant partner may not “sell on credit except that which it is always the custom to sell on credit—unless [both partners] stipulated this at the outset or [the active partner] acted with the other’s knowledge. If he deviates and acts without the other’s knowledge and afterward tells him, ‘I did such-and-such’ and [the stationary partner] consents to this, then the former is not held liable.”

The remainder of halakha 5:1 prescribes basic rules that had to be followed by an active partner in the absence of written stipulations. Since these were dependent on merchant custom—custom, to underscore again, that was general and not specific to Jews—they did not need to be ratified by the formal Jewish method of qinyan (symbolic confirmation of mutual agreement, typically by grasping either end of a piece of cloth or scarf and similar to a handshake). Rather, as Maimonides closes, “oral agreement alone is sufficient.” One may perhaps see here an allusion to a type of partnership attested in the Geniza, termed mu‘āmala, that could be established without the formal requirements of Talmudic law.⁴⁹

Seeking a parallel for Maimonides’ ruling in the halakha in question, R. Joseph Caro (Kesef Mishneh ad loc.) quotes Maimonides’ older contemporary R. Isaac b. Abba Mari of Marseilles in southern France, and later of Spain (ca. 1120–ca. 1190). In his digest of laws, Sefer ha-‘iṭṭur, R. Isaac cites a responsum of the Babylonian Gaon Kohen Ṣedeq (Gaon 926–935), stating that an active partner may sell on credit even without the investor’s permission if this is the “way [or custom] of the merchants,” orḥa di-tagarei, an Aramaic locution not found in the Talmud.⁵⁰ Like Arabic ḥukm al-tujjār, the Aramaic phrase describes the very same “custom of the merchants” that both the Geonim and Maimonides acknowledged as the extra-halakhic practice of the merchants.

2.4.1 Minhag Yadua‘ and the Custom of the Merchants

A more general and sweeping statement about the importance of the custom of the merchants—though again, not using the literal term—underlies a halakha in the Laws of Sales (Hilkhot mekhira). The halakhot at the end of chapter 26 there deal with local custom with regard to the designation of articles by an established name. Halakha 26:8 states: “It is an important principle in all business dealings that we follow the language of people in that place and [local] custom. In those places, however, where no recognized custom [minhag yadua‘] exists or specific names for objects, but rather some people call this object one thing while others call the same object by another designation, then we do as the Sages have expounded in these chapters.”

The phrase “recognized custom” (minhag yadua‘) includes one of the adjectives, yadua‘, used by the Geonim when referring to “custom.”⁵¹ Unknown in the Tannaitic and Talmudic corpus, it has the appearance of an Arabism, translating a word like ma‘lūm or ma‘rūf (“known” or “recognized”—the Arabic term for custom is ‘urf).⁵² These words are found together in a formula regarding custom in Islamic law.⁵³ In Maimonides’ language, minhag yadua‘ and minhag ha-medina are functional equivalents, an equivalence that may be Andalusian usage.⁵⁴ Maimonides explains that local custom applies in the present case precisely because every Jew “recognizes” its existence as an alternative to the received halakha.⁵⁵

* * *

In commerce, then, two realms existed side by side, according to Maimonides, as to the Geonim. First there was the realm of normative Jewish law (the halakha), as established in the Talmud; second was the realm of commercial custom. Jewish merchants in the Islamic world were thoroughly integrated into the wider commercial economy. In order to make a profit, in order to minimize risk, they were obliged to follow practices shared by all merchants, regardless of religion.

Under the rabbinic rubric of minhag ha-medina, Maimonides made room in his Code for this custom of the merchants—even if he did not always employ the term—in much the same way that early Islamic lawyers accommodated customs of the merchants in the developing Islamic legal canon during its formative period. Some of Maimonides’ adaptations to accommodate mercantile practice were minimal, entailing no fundamental challenge to basic Talmudic norms. They simply updated Talmudic language to fit the needs of the Islamicate marketplace. Other adaptations, often imperceptible, went further, actually expanding the halakha to fit the custom of the merchants. The most startling of these instances is the creation of an enforcement mechanism for the new economic institution of informal commercial agency (see Chapter 6). On occasion, as we shall see, Maimonides attempted to regulate a legal reform to make it conform with Talmudic norms. The outstanding case of this is his rejection of the Gaonic legal fiction designed to facilitate proxy legal agency in the post-agrarian Islamic world (see Chapter 7).