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I remember reading a responsum on the issue of agnostic Jew's serving as the tenth for a minyan, but do not remember the outcome. Does anyone know the rule?

Also, do we count, as the tenth man, a tinok shenishbah and one who does not understand the prayers at all?

  • If it is permitted, would it be different for a lower level of chiyuve (obligation) for a minyan such as Maariv?

  • If it is forbidden, would it be different for a higher level of chiyuve for a minyan such as Zimun, or someone who has a chiyuve for kaddish.

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Igros Moshe OC 1:23 –  sam Jul 30 '13 at 3:28

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