The Mishnah Berurah (47:28) writes that there is a difference of opinion among
poskim whether one who was awake all night recites
birkas haTorah in the morning. The Beiur HaGra (47:12) and Pri Chadash (47:12) are of the opinion that one does not recite a
bracha, while the Magen Avraham (47:12) and Elya Rabba (47:9) maintain that a
bracha is recited every day, even if one did not sleep. To avoid this uncertainty, it is best to hear the
bracha from one who slept, and answer Amen. If this is not possible, one should have in mind to fulfill the
mitzvah of
birkas haTorah when reciting the
bracha of
Ahava Rabba, and study Torah immediately after
Shmoneh Esrei. But what if one will not be
davening in the early morning, and wants to continue studying Torah? The Aruch Hashulchan (47:23) as well as other
poskim write that the common custom follows the Magen Avraham that a
bracha is recited, while the Mishnah Berurah maintains that a
bracha should not be recited because of the conflicting opinions.
Rebbi Akiva Eiger (cited by Mishnah Berurah 47:28) writes that if one slept a
shinas keva (i.e. a nap in a bed) on
erev Shavuos, even if he subsequently stays up all night, he may recite
birkas haTorah in the morning. Mishnah Berurah explains that this is true only if the person did not fulfill
birkas haTorah with the
bracha of
Ahavas Olam during
Maariv (i.e., he did not study Torah immediately after Maariv).
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