In Vayigash, Rabenu Bahya (also the Zohar) comments and says that the reason we had Asara Haruge Malchut because the brothers sold Yosef. However, Reuven didn't sell Yosef, so why should the corresponding Rabbi be punished for his actions?
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Me'am Loez says (citing Zohar Chadash, Eichah) that R. Eliezer is counted among these ten Sages. He was arrested and nearly sentenced to death, but was miraculously spared (Avodah Zarah 16b-17a); he thus corresponds to Reuven, who played a part in the whole drama but wasn't actually involved in the sale. |
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Maybe because he wasn't active enough in trying to stop them. Source: speculation. |
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The Torah Sheleima mentioned in this answer, while addressing another issue (why Reuven was also fined for the sale) says that Reuven was there when they threw Yosef in the pit, which lead to the sale. He is therefore also liable. It doesn't say it there, but not only was Reuven there, but it was his idea to throw Yosef into the pit. |
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I have heard that the 10th martyr is in place of, kavayachol, HaKadosh Baruch Hu, who acquiesced to the beit din shel matah and did not reveal the truth to Yakov. |
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