more halacot details of birkot hatorah

^ 7.The Beit Yosef 47:11 and 13 explains that according to the majority of poskim, any regular sleep is considered to be an interruption. Yet, he cites Rabbeinu Tam, Ram, and Talmidei Rabbeinu Yonah, who maintain that Birkot HaTorah last until the Shacharit prayer of the next day. Even if he slept a regular sleep, it is not an interruption. In practice, the Beit Yosef concludes that only regarding regular sleep during the day do we take into consideration the opinions which maintain that it is not an interruption. That is what is written in Shulchan Aruch 47:13. However, regular sleep at night is considered to be an interruption and it is necessary to recite the blessings after it. This is what the Pri Chadash 47:13 and many other Acharonim write, as well as the Mishnah Berurah 47:29, based on the absolute majority of the poskim. That is also what is written in Yabia Omer 8:5. Some Acharonim suggest compromises, such as reciting all Birkot HaTorah the first time and one berachah the second time (Shut Maharsham 3:337). However, according to the majority of poskim, one must recite all Birkot HaTorah after every regular sleep at night. What is the definition of regular sleep? The Rosh writes that sleep is considered regular when one goes to sleep on his bed. Bei’ur Halachah, section 4:16 writes that the middle opinion regarding sixty breaths taken while sleeping is approximately half an hour. See the note in Yabia Omer there.
Moreover, the Mishnah Berurah 47:25 writes that one who recites Birkot HaTorah after a regular sleep during the day does not lose out, because that is the opinion of the absolute majority of the poskim. (Additionally, according to most poskim, the obligation to recite Birkot HaTorah is biblical, and sefeika d’oraita l’chumra, when there is doubt concerning a biblical commandment, we are stringent.) Even so, the accepted minhag is not to recite the berachot. The Kaf HaChaim 25 writes in the name of the Ben Ish Chai, Vayeshev 12, that in order to avoid uncertainty it is best to recite the berachot in his thoughts. He further advises that while saying Birkot HaTorah in the morning one should have kavanah explicitly that they continue to last after sleep, for perhaps such kavanah will be effective. The Mishnah Berurah 13 suggests having kavanah to fulfill the obligation of Birkot HaTorah in the recital of Ahavat Olam in Ma’ariv, and after the berachah to say a verse for the sake of learning, for we learned in halachah 2 that Ahavat Olam is considered to be like Birkot HaTorah.
The opinion of the Ben Ish Chai , Vayeshev 13, also cited by the Kaf HaChaim 47:29, is that, according to Kabbalah, the law of Birkot HaTorah is similar to the law of Birkot HaShachar, that they are not recited twice in a 24-hour period. Their opinion is based on Rabbeinu Tam. However, according to Rabbeinu Tam, Birkot HaTorah are recited in the morning adjacent to Shacharit, and according to the Ben Ish Chai, if one slept twice at night, he recites the blessings after the first sleep and not after the second (and he should have kavanah in Ahavat Olam to fulfill the obligation of Birkot HaTorah). According to this, there is a certain distinction between Birkot HaShachar and Birkot HaTorah. Birkot HaTorah has two intentions: one, as part of Birkot HaShachar whose time starts after chatzot, and the second, as berachot before learning Torah. Therefore, one who wakes up close to chatzot should wait and recite Birkot HaTorah with Birkot HaShachar after chatzot. Yet, if he wakes up long before chatzot, he may recite them before chatzot alone. There were devout people who were accustomed even in such a case to wait and recite the blessings after chatzot.
^ 8.This is the Sephardic minhag, based on Rabbeinu Tam. One who was awake all night must be careful not to recite Birkot HaTorah before amud hashachar. Shut HaElef Lecha Shlomo 33 writes that if he recited them before amud hashachar his berachah is in vain and it must be repeated after amud hashachar. That is also what is written in Kaf Hachaim 47:29. The Tzlach in Berachot 11b is uncertain of this, and therefore the Yalkut Yosef 47:9 writes that if he recites the berachah before amud hashachar, he should have kavanah to fulfill his obligation in Ahavat Olam. (According to the Ben Ish Chai, those who are awake all night should recite Birkot HaShachar immediately after chatzot and only delay the recital of Birkot HaTorah until after amud hashachar.)
Concerning the Ashkenazic custom, the Mishnah Berurah writes that if one is not in the vicinity of someone whom he can hear recite Birkot HaTorah, he can have kavanah to fulfill his obligation in Ahavah Rabbah. That is based on the Chayei Adam in the name of Pri Chadash and the Gra. It is also the prevalent minhag. However, according to the Magen Avraham, Derech HaChaim, Eliyah Rabbah, and Shulchan Aruch HaRav 7, he should recite the blessings himself. That is what is written in Olat Ra’ayah p. 59, as well. The reason for this is because the obligation to recite the berachot is biblical and sefeika d’oriata l’chumra, (when there is doubt concerning biblical obligations, we are stringent). Obviously, one who wishes to rely on them is permitted to do so.

^ 9.So writes Mishnah Berurah 47:28, according to Rabbi Akiva Eiger, that in this case, all poskim agree that one must recite Birkot HaTorah. According to the Rosh, this is because after a regular sleep during the day he is obligated to recite the berachot, and according to Rabbeinu Tam, because the new day has arrived.