The Rama (Rav Moshe Isserles of Cracow, 1530-1572), in Orah Haim (551:10), presents the well-known Haacha that although it is customary to refrain from meat during the Nine Days (from Rosh Hodes Ab through Tisha B’Ab), meat may be eaten during this period at a Se’udat Misva – a meal that is a Misva. Specifically, the Rama says that meat may be eaten at a Berit Mila, Pidyon Ha’ben, Se’udat Erusin (celebration of an engagement), and a Siyum.
Unfortunately, this final case – a Siyum – is one which many people inappropriately take advantage of, finding ways to have a Siyum during the Nine Days in order to permit the consumption of meat. The Mishna Berura (Rav Yisrael Meir Kagan of Radin, 1839-1933) writes very clearly that a number of conditions apply for meat to be allowed at a Siyum celebration during the Nine Days. First, he writes, the Siyum must not have been specifically planned for the Nine Days. Some people complete a Masechet earlier in the year but leave the last several lines so they could formally finish the Masechet during the Nine Days and thus make a Siyum with meat. This is improper. Conversely, some people rush through a Masechet, learning it much at a much faster pace than their normal course of study, in order to ensure to complete it during the Nine Days. This, too, is not a legitimate practice. Meat may be eaten at a Siyum celebration only if it happened to occur during the Nine Days, and not if it was intentionally scheduled for this period.
Secondly, the Mishna Berura writes, meat is allowed at a Siyum only if the individual would normally eat and serve meat when making a Siyum. If a person normally celebrates a Siyum with some cake and drinks, he cannot then have a meat meal to celebrate a Siyum during the Nine Days.
Thirdly, the Mishna Berura states that one who celebrates a Siyum during the Nine Days with a meat meal may invite only those whom he would normally invite to a Siyum. This includes, of course, his wife and immediately family members, and close friends, but he cannot then include anybody who wishes to join in order to be allowed to eat meat. Moreover, during Shabua She’hal Bo – the week of Tisha B’Ab – one is allowed to invite to his meat meal only ten close friends. Once the week of Tisha B’Ab begins, the rules become stricter, and thus during this week, one who makes a Siyum and celebrates with a meat meal may invite only ten close peers to participate.
An interesting question arises in the case of a woman who makes a Siyum – such as if a woman learned a section of Mishnayot, or completed the in-depth study of Pirkeh Abot with commentaries, or the in-depth study of a Sefer of Humash with commentaries. In such a case, it is certainly appropriate for the woman to make a Siyum to celebrate her accomplishment, but the question becomes whether meat is allowed at such a Siyum during the Nine Days, and whether the woman’s husband and other family members may attend.
The conceptual issue at stake is the precise definition of "Se’udat Misva," the kind of meal at which meat is allowed during the Nine Days. There are two categories of Misvot: "Misva Hiyubit" – an obligatory Misva act; and "Misva Kiyumit" – an action which is not obligatory, but for which one is credited with a Misva and for which he will be duly rewarded. Torah study is obligatory for men, but women are exempt from this Misva, though they earn reward if they learn. The question thus becomes whether even a "Misva Kiyumit" suffices for a celebration to qualify as a "Se’udat Misva" at which meat is allowed. The examples given by the Rama are all obligatory Misvot – Berit Mila, Pidyon Ha’ben, Se’udat Erusin (marriage is an obligatory Misva), and Torah learning for men. But does the category of "Se’udat Misva" also include the celebration of an optional Misva?
Proof may perhaps be drawn from one opinion in the Rishonim explaining an account in the Gemara in Masechet Baba Kama. The Gemara there talks about a number of Rabbis who participated in a party celebrating "Yeshu’a Ha’ben" – literally, "the salvation of the child." Rashi (Rav Shlomo Yishaki, France, 1040-1105) explains that this was a Pidyon Ha’ben, and the word "Yeshu’a" here means "redemption." Tosafot (commentaries by Medieval French and German scholars), however, explain that this was a meal celebrating a child’s birth. Childbirth marks the infant’s "salvation" from the confines of the uterus, and thus the birth itself – even before the Berit – was celebrated as a "Yeshu’a Ha’ben." The Terumat Ha’deshen (Rav Yisrael Isserlein, 1390-1460) writes that this account forms the basis of the Ashkenazic custom to celebrate a "Shalom Zachor" – a special party on the first Friday night after a boy’s birth. Moreover, the Terumat Ha’deshen adds, one of the Rabbis whom the Gemara speaks of participating in this celebration is Rav, who, as we know from other sources, never participated in a party which was not a Se’udat Misva. Necessarily, the Terumat Ha’deshen concludes, this celebration after a boy’s birth is considered a Se’udat Misva. (Although, one might refute this proof by suggesting that Rav attended but did not eat.)
Clearly, even according to the Terumat Ha’deshen, who considers this celebration a Se’udat Misva, it is not obligatory. Hence, we might deduce from the Terumat Ha’deshen’s discussion that even non-obligatory Misvot qualify for a meal to be considered a Se’udat Misva.
Indeed, a number of Poskim ruled that if a woman makes a Siyum during the Nine Days, she may eat meat, and her husband may participate:
Summary: Although meat is allowed at a Siyum during the Nine Days, three conditions must be met: 1) one did not intentionally schedule the Siyum for the Nine Days; 2) one normally eats and serves meat when he makes a Siyum; 3) one invites only those whom he would normally invite to a Siyum. During the week of Tisha B’Ab, only ten close friends may participate in a meat meal at a Siyum celebration. If a woman makes a Siyum during the Nine Days, such as after completing a section of Mishna, or a Sefer of Humash which she studied in depth with the commentaries, she may eat meat, and her husband may participate.