Does Rashi's commentary on a quoted mishna reflect the true explanation?

Question

Often the Bavli will quote a mishna from another maseches (tractate) or another part of the same maseches. Does Rashi's commentary on the Bavli's quotation of the mishna reflect his interpretation of the mishna per se, or does it reflect only his interpretation of the mishna as used in the Bavli? In other words, where there is ambiguity in a mishna, multiple ways to read it, does what Rashi writes when the mishna is quoted somewhere reflect only his belief as to how the Bavli reads it (and so any inconsistency is only a problem if it carries through to the Bavli's conclusion), or does it reflect his belief as to what the mishna itself means (and so should be consistent every time the mishna is quoted)?

I strongly suspect the former is true: in particular, I seem to recall having seen instances where a mishna is interpreted by Rashi in a way that satisfies only the initial theory ("hava amina") of a passage in the Bavli. But I can't think of any example of this, and would like some evidence one way or the other.

Answer 1

Look at the Haga'ot HaGRI"V 26 on the "Klalim B'Rashi", printed after the Mavo LaTalmud, at the end of Masechet Berachot.

He says:

‫דרך רש״י בהרבה מקומות לפרש המשנה כס״ד דמקשן כדי להבין המשנה כס״ד טרם בואו אל המסקנא וזהו אך דרך‬ ‫רש״י לא כן שאר מפרשים תוי״ט פ״ב דפאה מ״ב‬

‫

It is Rashi's way in many places to explain the Mishna according to the initial theory before the conclusion is reached. This is the way of Rashi, other commentaries do not do this. - Tosfot Yom Tov Pe'ah 2:2

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I didn't look it up, but in a letter from the Lubavitcher Rebbe to R' Shlomo Yosef Zevin (Igrot Kodesh vol2, letter 295), the Rebbe writes:

‏וידוע אשר רש"י מפרש הוא ולא פוסק ובפירושיו רגיל לפרש יותר קרוב‏ לפשוטו אע"ג דלית הלכתא הכי (ביד מלאכי כללי רש"י המקורים. ועוד).‏

Loosely translated:

Rashi is not a Posek, and will often give more literal translations, even if they are not according to Halacha. -- See Yad Malachai's rules of Rashi and others.

Answer 2

Rashi's shittah is to explicate the gemara - not to provide a stand-alone peirush on the Mishna. As such, you will find that his interpretation of any given mishna will vary depending on the context in which the gemara is quoting it. To give you an example, consider Shevi'it 4:10. There, the mishna asks and answers a question as follows:

מאימתי אין קוצצין האילן בשביעית? בית שמאי אומרים: כל האילן משיוציא

At what point is one not allowed to chop down trees in the seventh year? According to the school of Shammai, as soon as it produces.

Produces what? It is the Rambam's opinion (and that of the Bartenura) that this is a reference to the production of foliage - which occurs, the Bartenura states, during Nissan. By way of contrast, Prof. Hanoch Albeck understands the mishna to be referring to the time when trees begin to produce fruit. What does Rashi say? As is noted by R' Shlomo Adeni (Melekhet Shlomo), Rashi is contradictory.

In Berakhot 36b, this mishna is quoted in the context of delineating which parts of fruits are shomrim to the rest (ie: that which might not normally be considered an actual part of the fruit, but which combines with the rest for the purpose of rendering it tamei). Rashi explicates the mishna as follows:

משיוציא. את הפרי

As soon as it produces: its fruit.

Compare that to Pesachim 52b, where the context more directly relates to the point at which trees in the seventh year are forbidden from being cut down. There, Rashi says the following:

משיוציאו: תחילת העלין בימי ניסן

As soon as they produce: the first of their foliage during Nissan.

Answer 3

Besides for the Tosafos Yom Tov cited by @Menachem there are a couple of other sources:

R. Yechezkel Landau, in his commentary to Berachos 20a, writes:

ונראה לפי הכלל שאני רגיל לומר לתלמדיי שדרכו של רש"י תמיד בהמשניות לפרש המשנה לפי ההוה אמינא של המקשה ולא לפי המסקנא כדי שיהיה שייך סוגית הגמרא על המשנה כסדר

And this is apparently in accordance with the rule that I am wont to tell my students, that the methodology of Rashi in Mishnayos is always to interpret the Mishnah in accordance with the original assumption of the questioner, and not according to the conclusion, in order to make sense of the Gemara's explanation of the Mishnah in order.

Similarly, R. Akiva Eiger writes in his commentary to the first Mishnah in Yevamos:

זה מספיק ליישב דברי רש"י דרגיל לפרש כפי הס"ד דבזה מתפרש ומובן יותר השקל׳ וטריא כמ"ש תי"ט פ"ב דפיאה (ובנ"י כתב והרשב"א תמה על פירש"י וכו' ובאמת ליכא קושיא כ"כ די"ל כנ"ל) אבל על הרע"ב אינו מספיק דצריך לפרש כפי המסקנא

This suffices to uphold the words of Rashi, for he is wont to explain according to the original assumption because then the back-and-forth is clearer, as the Tosafos Yom Tov writes in the second chapter of Peiah. (And the Nimukei Yosef writes that the Rashba was astounded by Rashi etc. But in truth it is not such a question, because one can say as was just mentioned.) But for R. Ovadiah of Bartenura it does not suffice, because he has to explain according to the conclusion.

Answer 4

First of all, there's no one "true" explanation of a Mishnah. There could easily be more than one explanation of a given Mishnah.

This is the benefit of the Gemaras that have "Likutei Rashi" or "Musaf Rashi" on the sides that quote Rashi from other Masechtos that discuss the same phrase/Mishnah brought in the current Gemara. Oftentimes Rashi will have more than one approach to learning a given Mishnah; see, for instance, his three different approaches in Bava Kama 57a, Bava Metzia 41b, and Bava Metzia 84b regarding the concept of "Karna b'lo shevuah adifa mikefeila b'shevuah." A close reading should indicate, at least the way I read it, that all three of these explanations argue on each other. (Just an example off the top of my head; not a quote from a Mishnah whatsoever.)