Choreish 3 - Practical Examples 1 (Klal 10 Siman 3) Hilchos Shabbos - S0330

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We are learning the melacha of choreish. We have finished the simanim of the Chayei Adam and will discuss some practical examples. 

If a person has a dirt backyard, and they set up their sukkah on the dirt, there are potential concerns of choreish. In Klal 9, we discussed the concept of davar she’eino miskavein, and one of the examples given was dragging a chair or couch along the dirt and making a furrow while doing so. We learned that if it is a psik reisha (ie, it is definite that it will happen), it is assur. If it is not clear it will happen, it is a davar she’eino miskavein and muttar. 
Over here, the question comes up when a person wishes to move around their chairs or tables in the sukkah. Even though davar she’eino miskavein is muttar, if it is a psik reisha, it will be assur. Even though in cases that are a psik reisha, it would arguably only be assur as a melacha she’eina tzricha legufa (because one does not plan to plant there). However, the fact that one does not plan on using the hole does not change anything, because it is a place which is susceptible for planting, so it is still assur.

Pushing a baby carriage over soft ground may create a furrow on the ground, and would seem to fall under the melacha of choreish. However, we learned that the point of choreish--and the situations in which it is assur--is not just making a hole, but facilitating the ground for planting. Thus, the Gemara in Beitzah (23a) points out that when one pushes a baby carriage, they are actually compressing the ground, and making the area which was previously susceptible to planting less susceptible to planting. The Gemara calls this kovesh es hakarka. Thus, one may push a carriage over soft dirt, since it only compacts the ground and does not facilitate planting.
However, the Orchos Shabbos points out that if one changes directions quickly with a stroller, the wheels scrape sideways against the earth and may actually loosen the earth. One should be more careful to change directions slowly to avoid this concern.

Based on this idea, it should not be assur for a woman wearing high heels to walk on soft dirt, since the dirt underneath the heel becomes compacted from the heel, rather than softened. 

If a person sets up their sukkah on top of grass, they also have the concern of liquids spilling on the grass during their seudos, which would fall under the issur of zoreah. It is preferable to place the sukkah on top of cement. If one places their sukkah on top of a dirt area which does not have vegetation, if liquid spills onto the dirt, it arguably will not be zoreah, since there is no vegetation. However, it will still fall under the issur of choreish, since the liquid causes the ground to loosen. 

Summary
Some practical examples of choreish include:
Dragging benches or chairs within a sukkah;
Pouring or spilling liquids onto dirt where there is no vegetation.
High heels and carriages are not an issue of choreish, because they compact the ground rather than soften it.