Is sugfaniyot dough obligated in challah?

Answer

Dough becomes obligated in challah only when it is considered “bread” (Pesachim 37b), as it is written: “When you eat of the bread of the land” (Bamidbar 15:19). Furthermore, any dough baked in an oven is considered "bread," as is written: “Ten women shall bake your bread in one oven” (Vayikra 26:26).

The Amora'im disputed that status of dough baked in a pan (ilpas, a casserole or stew pot; Pesachim 37a). The Shulchan Aruch (YD 329:2) rules such dough is obligated in challah. Yet, the Yerushalmi (Challah 1:3) states that dough cooked in a pan containing liquid—whether fried in oil or boiled in water—is not considered bread and is therefore exempt. The Shulchan Aruch rules likewise. In light of the above, classic sufganiyot fried in oil are exempt from challah.

However, Rabbeinu Tam (cited in Tosafot, Pesachim 37) maintains that frying in oil exempts dough only when a soft batter is used. If one prepares a thick dough, like bread dough, it becomes obligated in challah at the moment of kneading, and frying does not exempt it. Accordingly, sufganiyot would be obligated in challah, since their dough is thick at the time of kneading.

On the other hand, the Rash (Challah 1:5) maintains that if the intention from the outset is to fry the dough in liquid, the dough is exempt from challah even if it is thick—unless a portion of it is baked in an oven, in which case the entire batch becomes obligated. According to his view, sufganiyot are exempt from challah if the entire dough was made with the intention of frying in oil.

Due to this dispute, Maharam of Rothenberg (cited by Rosh, Pesachim 2:16) instructed his household members that if they wish to knead a thick dough with the intention of cooking or frying it in water or oil, a small portion should be baked in the oven so that the entire dough becomes obligated in challah according to all opinions.

In practice, the Shulchan Aruch (YD 329:3–4) rules like Rabbeinu Shimshon: any dough prepared with the intention of frying is exempt from challah. However, the Shach (YD 329:4) writes that one should separate challah without a blessing, to consider Rabbeinu Tam's opinion or follow Maharam’s practice mentioned above.

In conclusion: If preparing a batch of dough intended for frying sufganiyot when the dough contains the required amount for challah, separate challah without a blessing. However, if intending to bake part of the dough in an oven, the entire batch becomes obligated, and challah should be separated.