Determining Which Torah Scroll Should Be Returned First When the First Scroll Is Also Used for Maftir

Question:
On a day of three Sifrei Torah where only two are available and the first Torah scroll taken from the ark was also used as the third scroll for Maftir, which scroll should be returned to the ark first? Should the second scroll be returned first, being that it was removed last, or should the Maftir scroll be returned first, even though it was removed first?

Answer:
In such a case, it is preferable to return the Maftir scroll first, even though it was originally the first scroll removed from the ark.

Explanation:

The custom of returning the second scroll first when two Sifrei Torah are removed from the Ark is first mentioned in Sha’arei Ephraim, though no explicit reason is provided. Two interpretations exist:

1. Order-Based Approach (First Out, Last In): The first scroll removed should be the last returned, maintaining the original order inside the ark. This interpretation understands the custom as maintaining the original order of the scrolls inside the ark. According to this view, the first scroll removed should be the last one returned, so that the arrangement inside the ark remains consistent.

Implication: If the first scroll was also used for Maftir, then the second scroll should be returned first, leaving the first scroll to be returned last.

1. Usage-Based Approach (Last Used, First Returned): The scroll most recently used and closest to the reader should be returned first. This interpretation sees the custom as prioritizing the scroll most recently used. Since the Maftir reading concludes the Torah reading, the scroll used for Maftir should be returned first, regardless of when it was originally removed from the ark.
   Implication: If the first scroll was also used for Maftir, then it should be returned first.

The second interpretation appears more plausible. Therefore, when the first scroll was also used for Maftir, it should be returned first.

Source:

See our corresponding Sefer “The Laws of Kerias Hatorah” Chapter 11 Halacha 7D!; Shaareiy Efraim 10:41; Piskeiy Teshuvos 149:4; Koveitz Avkas Rochel 8:183-191