OPINIONS: Rebbi Yochanan and Reish Lakish argue whether the obligation to separate Chalah applies to dough cooked in a pot. Is such dough defined as "bread" or not? Reish Lakish says that it is exempt, while Rebbi Yochanan says that it is obligated. What is the Halachah?
(a) RABEINU CHANANEL rules like Reish Lakish who says that the dough is exempt, because the Amora'im (end of 37b) seem to favor his opinion.
(b) However, the RIF, TOSFOS, and the ROSH point out that whenever Rebbi Yochanan and Reish Lakish argue, the Halachah follows the view of Rebbi Yochanan (Yevamos 36a). Accordingly, Chalah must be separated from dough cooked in a pot.
HALACHAH: The SHULCHAN ARUCH (YD 329:2) rules in accordance with Rebbi Yochanan, who says that Chalah must be separated from dough cooked in a pot. This ruling applies even though the dough was placed inside the pot and afterwards the pot was heated.
The Poskim point out that when the dough is cooked in a pot that contains liquid, everyone agrees that the dough is exempt from Chalah, because the product is not bread-like but rather it is a cooked dish. However, this exemption applies only when the dough itself is a "Belilah Rakah," a loose dough, and not thick and bread-like. If the dough is thick like the type normally used for baking bread, then whether or not the obligation of Chalah applies to it is subject to another dispute among the Rishonim.
1. Chalah must be separated from the dough at the time the dough is kneaded. Accordingly, it should make no difference what is done to the dough afterwards. Since it was obligated from the time that it was kneaded, even if it is eventually baked in the sun and not in an oven it should not lose its obligation of Chalah.
For this reason, RABEINU TAM (cited by Tosfos DH d'Chulei) asserts that Chalah must be separated from a thick dough, regardless of how it is eventually baked, cooked, or prepared to be eaten. Moreover, Rabeinu Tam adds that when one eats any baked product made from a thick dough (from which Chalah needed to be separated), he should recite the blessing of "ha'Motzi," since it has the status of bread.
2. The RASH (cited by the Rosh), however, does not accept Rabeinu Tam's ruling. Even if the dough is thick, it is not necessarily obligated in Chalah. The obligation of Chalah depends upon the intentions of the person who kneads the dough. If the person kneads the dough in order to bake the dough in the sun, it is exempt from Chalah. If he kneads it in order to bake in a pot, its obligation of Chalah depends on the dispute between Rebbi Yochanan and Reish Lakish.
Based on various sources in the Gemara, the Rash qualifies his ruling and adds that there are times when thick dough is obligated in Chalah even if one intends to bake it in the sun. For example, if one intends to bake most of the dough in the sun, but he has in mind to bake some of it in an oven, then the entire batch of dough is obligated in Chalah.
The SHULCHAN ARUCH (YD 329:3) cites the opinion of the Rash and writes that the obligation of Chalah depends on the intention of the person who kneads the dough.
However, the SHACH there (329:4) notes that the MAHARAM (cited by the Rosh) chose not to issue a conclusive ruling on the matter. Instead, the Maharam recommended that when one makes a thick dough but does not intend to bake it in an oven, he either should separate Chalah without a blessing, or he should have in mind to bake at least some of the dough and thereby obligate himself to separate Chalah even according to the opinion of the Rash. The Shach says that this is the recommended practice today.