Bhikkhuni Ordination Validity



Collected Responses

to Ajahn Thanissaro's and Wat Pah Pong's 

Concerns on Bhikkhuni Ordination Validity







Four women from Dhammasara Nuns' Monastery in Perth Australia were fully ordained as bhikkhunis in the Theravada tradition at Bodhinyana Monastery on October 22, 2009 by the dual ordination proceedure (bhikkhuni upasampada kammavaca) of the Pali texts.  They were ordained first by eight members of the Theravada Bhikkhuni Sangha and then directly afterwards their ordination was confirmed by ten members of the Theravada Bhikkhu Sangha, thus fulfilling the qualifications for a dual ordination.  The ordination proceedings were prepared and reviewed beforehand for orthodoxy and accuracy by a team of Vinaya scholars, and were audited during the ordination by Ven Ayya Santini Theri.  Afterwards, on request, the ordination proceedings were shared with Wat Pah Pong Monastery in Thailand for their review.


On request of the Administrative Council of Wat Nong Pah Pong, Ajahn Chah's monastery in Thailand, well-known Vinaya scholar and author Thanissaro Bhikkhu reviewed the ordination proceedings and then wrote a letter in which he proposed a potential and tentative inferential theory on Vinaya for consideration of the World Abbots Meeting (WAM) at Wat Pah Pong in December 2009.  This letter was concerned with whether the recent full bhikkhuni ordination of four women in Australia could be determined invalid according to the Buddhist Monastic Discipline of the Pali-text Vinaya, the rendition of the Vinaya learned and practiced by Theravadan Buddhist traditions around the world.  It is important to undersand that the contents of this letter were requested for the sake of discussion and consideration of the WAM and where not meant to be an absolute proclamation, verdict or declaration or any sort. Ajahn Thanissaro was called upon as a consultant. Despite the great respect in which Ven Thanissaro is held for his scholarship, he is not in a position of authority regarding Vinaya within the Wat Pah Pong community and its affiliates, nor within the many Orders and Communities of Theravada Buddhism other than his own. Each of these Communities (Sanghas) and Orders (Nikayas) have their own responsibility and authority to decide internally upon issues of Vinaya.  Whether Wat Pah Pong determines the ordinations to be considered valid for their own community or not does not legally effect the ordinations validity within the greater International Buddhist Sangha.



Ajahn Thanissaro's Letter


Ven Thanissaro Bhikkhu's letter, originally sent to former abbot of Wat Pah Nanachat (International Forest Monastery) Ajahn Nyanadhammo, has been posted on the Dhammalight website for public review.  Ajahn Thanissaro's letter on the Dhammalight site is linked to here and can be accessed by clicking on his name.  (If the link does not work, go to -> "Vinaya Issues".)



Buddhist Scholars' Response


In response to this internet publication, a number of Theravadan Buddhist scholars and Vinaya scholars have reviewed Ajahn Thanissaro's work and, notably, have NOT found his argument valid, nor come to the conclusion he proposed.  Rather, the conclusion of each of these scholars has been contrary to Ven Thanissaro's in this case, that is, finding no reasonable precedent in Dhamma or Vinaya to consider the new bhikkhunis' ordinations invalid.


Counter responses so far have been offered by the Buddhist Elders, bhikkhus and bhikkhunis below.  Ven Bhikkhu Bodhi is one of the most eminent scholars of the Pali texts in the modern world. Internationally acclaimed Buddhist teacher, author, Vinaya scholar and meditation master Ven Ajahn Brahm is the Abbot of Bodhinyana, the monastery where the ordinations took place.  Ven Ajahn Brahmali is the resident Vinaya Acarya of Bodhinyana Monastery.  Ven Ayya Tathaaloka served as the Preceptor (pavattini) for the bhikkhuni ordinations and is a scholar of Comparative Bhikkhuni Vinaya and History of the Bhikkhuni Sangha.  Ven Bhikkhuni Sudhamma is a former lawyer as well as a Vinaya scholar, practitioner and author on the subject. 


Click on the titles below to read the responses:


    - Ven Bhikkhu Bodhi: Formalities of the Law, Qualities of the Heart

    - Ven Ajahn Brahm: The Vinaya Rules and the Perth Bhikkhuni Ordination

    - Ven Ajahn Brahmali: Response to Ajahn Thanissaro's Letter (version 2 - replaces the former)

    - Ven Ayya Tathaaloka Bhikkhuni: Bhikkhuni Preceptor's Response

    - Ven Sudhamma Bhikkhuni: A Bhikkhuni's Response to Ven Thanissaro's Theory


Additional Responses are still coming in and may continue to be posted here:


    - Ven Inamaluwe Sri Sumangala Maha Nakaya Thera: Rangiri Dambulla Higher Ordination

      (Chief Prelate of the Rangiri Dambulla Bhikkhunin Chapter of Sri Lanka)

    - Ven Jestunma Tenzin Palmo: No Bhikshunis in the World?

    - Ven Ajahn Sujato: Ajahn Thanissaro's Letter on Bhikkhunis




(We are experiencing difficulty with the links on this site. If the links to Ven Bhikkhu Bodhi's, Ven Ayya Tathaaloka's and Ven Bhikkhuni Sudhamma's Responses do not work and you are interested in reading them, please either go to "Files" on this site and access them directly, or see directly below.)



Ven Bhikkhu Bodhi: Formalities of the Law, Qualities of the Heart


Formalities of the Law, Qualities of the Heart:

A Response to Thanissaro Bhikkhu’s Letter of Nov. 13, 2009

In his letter of November 13th Thanissaro Bhikkhu objects on grounds of formal procedure to the validity of the bhikkhuni ordination held in Western Australia on October 22nd. I do not think his objections can withstand examination.

The crux of his argument concerns the bearings that Bhikkhuni Pacittiya 83 has on the legitimacy of the proclamations proposing the candidates for admission to the Sangha. Pacittiya 83 assigns a pacittiya offense to a bhikkhuni who ordains more than one pupil a year. According to Ven. Thanissaro, since proclamations that propose two candidates under a single sponsor (pavattini) would necessarily violate this rule, the proclamations are illegitimate and therefore the ordination is invalid.

In evaluating this critique, we should first note that nothing in the formulation of Bhikkhuni Pacittiya 83 or its analysis declares that a second pupil ordained by the sponsor (pavattini) in the same year is anupasampanna, “not ordained.” This contrasts significantly with the case of Bhikkhu Pacittiya 65, which ascribes a pacittiya offense to a bhikkhu who ordains a man under the age of twenty and then adds, of the man who went through the forms of ordination, “and that person is not ordained” (so ca puggala anupasampanno). Thus the verdict that the candidates are not validly ordained is inferential. It is an inference that extends beyond what is stated in the text of the Vinaya itself. It is not supported by a fitting analogy with an established precedent in the text and it is therefore questionable that we need affirm it.

We should note that an act of ordination does not have to be perfect in all respects in order to be valid. There are in fact several cases mentioned in the Bhikkhuni Vinaya in which a defect in the ordination procedure does not invalidate the ordination itself. For example, Bhikkhuni Pacittiyas 63 and 64 require that a candidate for ordination should have trained “for two years in six special rules” and received authorization from her Sangha to take ordination. However, the "variant cases" sections attached to these rules establish that ordination given to a candidate who has not fulfilled these requirements can still be valid (dhammakamma). According to these rules, the preceptor receives a pacittiya for conducting the ordination while the other bhikkhunis who participate incur dukkaṭas (a very minor type of offense), but, other things being equal, the ordination remains valid and the candidate emerges a bhikkhuni.

If, under Bhikkhuni Pacittiya 83, the Buddha intended to annul the ordination of the women who were ordained subsequent to the first, in the same year under the same sponsor, it seems almost certain that this would have been stated in the rule itself, as is done in Bhikkhu Pacittiya 65. If this is not stated in the rule, we would expect that the Sutta Vibhanga would have made this point in its analysis of the rule. The fact that nothing of this sort is said in either rule or analysis suggests that, despite the procedural fault, the ordination conferred on the second pupil, and on subsequent pupils in the same year, remains valid. The sponsor incurs a pacittiya, of course, and the other bhikkhunis who constitute the quorum incur dukkatas. But the ordination itself is not invalidated.

Ven. Thanissaro contends that the invalidity of the ordination stems from the fact that the proclamations used to conduct the ordination violate a rule. In his view, this flaws the proclamations themselves, and since the proclamations are faulty, he holds that the ordination they are intended to execute must be invalid. In support of this hypothesis, he points out that the Parivāra, the last book of the Pali Vinaya Pitaka, mentions several cases in which an ordination is said to “fail” (vipajjati) because of faults in the proclamations. But there is a significant difference between the faults pointed out by the Parivāra and the faults in the case under consideration. The faults that the Parivāra says annul an ordination are those in which the names of the candidate and/or his preceptor are omitted, or in which a reference to the Sangha is omitted. In such cases, if we confine our attention to the words of the proclamation themselves, we would see that, while the intentions of the participants might be understood, the words fail to fulfill the act of ordination. They fail to propose a candidate for ordination, or they fail to mention the preceptor under whom the candidate desires ordination, or they fail to state that he seeks ordination from the Sangha of bhikkhus. In these cases, judging from the wording of the proclamations, we would have to conclude that no candidate has been proposed for ordination, or that no preceptor has been proposed, or that it has not been clearly stated that the candidate seeks admission to the Sangha of bhikkhus. These are the essential components of an act of ordination, and it is thus inevitable that a proceeding that does not mention them would be judged a failure.

However, when two women candidates for bhikkhuni ordination are proposed under a single sponsor--providing that their names are stated, the name of the sponsor is stated, and it is said that they desire admission to the Sangha—all the components of a meaningful proclamation are present. Thus, while the proclamations entail a pacittiya, they do not omit the essential factors of an ordination. Although the violating of a pacittiya rule is certainly regrettable from the standpoint of protocol, there is no compelling reason to think the violation is weighty enough to undermine the validity of the ordination.

Ven. Thanissaro further says that “the act of adhering to the authorized forms for Community transactions is one of the few ways we have of showing to ourselves and others that we are deserving of the Buddha’s trust. This is why the Canon is so insistent that the forms be followed accurately.” I agree with Ven. Thanissaro that under all normal circumstances formal procedures should be followed as scrupulously as possible. It is through the container of forms that the nectar of the Dhamma is prevented from slipping away. However, it seems to me that it would be contrary to the spirit of the Buddha’s teaching to use a very minor procedural defect as a ground for retracting the ordination of a candidate who possesses all the requisite qualifications and has entered the Sangha with sincerity of purpose. This is especially the case when it is unclear that the procedural defect itself is grave enough to annul the ordination. Given that the Buddha himself established the Bhikkhuni Sangha, and entrusted the bhikkhus with the responsibility for confirming a bhikkhuni’s ordination, for advising and instructing the bhikkhunis, and for seeing that their material needs are met, I think it would be a much more serious violation of the Buddha’s trust to use minor procedural technicalities to obstruct the growth of this branch of the Sangha in this very early stage of its revival. Rather, our endeavor should be to encourage its growth and ensure that it thrives in a healthy atmosphere of trust and support.

Near the end of his letter, Ven. Thanissaro writes: “This is why the forms are so important for mutual respect, harmony, and trust—all qualities of the heart—in the Community at large.” When I read this sentence, I could not help but ask myself: “Is strict adherence to legalistic protocol the most effective way to nurture the ‘qualities of the heart’? Wouldn’t the ‘qualities of the heart’ be much more effectively nurtured by giving primacy to those virtues such as loving-kindness, compassion, and generosity of spirit that enable us to transcend self-concern and offer the most bountiful help to others who, like ourselves, aspire to reach the fruits of liberation?” As I see it, while we should do our best to respectfully maintain the forms of the tradition, we should not let a narrow formalism become the basis for denying to humanity’s “other half” the opportunity to lead the holy life in the way the Buddha­­ himself intended women to live it, that is, as fully ordained bhikkhunis.

I should close by stating that the above comments concern only the question of whether the legality of the Australian ordination was undercut by the procedural fault of violating Bhikkhuni Pacittiya 83 in the proclamations. They are not intended to legislate on the question whether it was appropriate for this ordination to have been conducted at the time and under the circumstances in which it took place. That is an altogether different issue which I am not in a position to comment on, as it concerns a system (the Thai ecclesiastical order and its procedural principles) to which I do not belong.


Bhikkhu Bodhi

25 November 2009


    - Ven Ajahn Brahm: The Vinaya Rules and the Perth Bhikkhuni Ordination



The Vinaya Rules and the Perth Bhikkhunī Ordination

The recent argument by the respected monk and scholar, Ṭhanissaro Bhikkhu, suggests that the recent bhikkhunī ordination in Perth was invalid on the basis of Vinaya (the monastic legal code). While I admire his scholarship and dedication to Buddhism in the West, there are grounds for looking at the matter in a different way.

The length and complexity of Ṭhanissaro Bhikkhu’s paper demonstrates that it is a difficult argument to prove. Any argument that is based on the principle of comparing authoritative statements on the Vinaya by the Buddha, and teasing out their meaning, will always be ambiguous. Inferences can travel alternative paths and lead to very different conclusions.

For example, bhikkhunī pācittiya 83 gives a pācittiya to a female preceptor who ordains more than one bhikkhunī per year and a dukkata to the other nuns who participate in the ceremony. Conspicuous by its absence, in both the Piṭaka and the commentary, is any statement that those thus ordained are not valid bhikkhunīs. This can be compared to the monks’ pācittiya 65 that gives a pācittiya to a male preceptor who ordains someone underage, a dukkata to the monks who participate in the ceremony, and there is a statement that the ordination is invalid. One can infer, from comparing these two rules, that if the Buddha had intended a breach of bhikkhunī pācittiya 83 to make the ordination invalid, then he would have stated so.

About thirty years ago, I coined the term “grey areas of Vinaya”. The question posed by Ṭhanissaro Bhikkhu - “is a sanghakamma invalid when one of the participants knows that a rule is being broken” - is a nice legal point, but clearly qualifies as a grey area of Vinaya. It has become wise practise for the Sangha, when faced with grey areas of Vinaya, to follow the more compassionate interpretation. The respected Thai scholar Phra Brahmagunabhorn (P.A. Payutto), stated to me that “the knowledge and observance of the principles, esp., of the Vinaya rules should be as complete as possible on the one hand, and the matter should be treated with as best Metta and compassion (sic.) as possible on the other. Decision should be made by the Sangha that is best informed and compassionate.” Such is especially advisable in the current case where the reason for the original pācittiya offense, a temporary situation of crowding in the Bhikkhuni Monastery close to the Jeta Grove, hardly applies in present times.

So, may the fourfold assembly recognise this as a grey area of Vinaya and choose the more compassionate path.

Ajahn Brahm

Monday, 23rd November 2009





    - Ven Ajahn Brahmali: Response to Ajahn Thanissaro's Letter (version 2 - replaces the former)



A Response to Ajahn Thanissaro’s Letter on the Simultaneous Ordination of 2 or 3 Bhikkhunīs (version 2)



In his public letter of 13th November 2009, Ajahn Thanissaro makes the case that ordaining 2 or 3 bhikkhunīs simultaneously is invalid and, consequently, so was the recent ordination in Perth. I am not persuaded by Ajahn Thanissaro’s argument, and the rest of this letter is an attempt to substantiate why.


First of all, I agree with Ajahn Thanissaro (see part 12 of his letter) that saṅghakamma should be done without invalidating defects and that it is not satisfactory to deviate from clearly established principles of Vinaya on grounds of compassion.[i] It follows that if the ordination performed in Perth can be shown to be invalid in such a way, I would certainly accept that. (Ajahn Brahm has specifically told me that this is his position too.) From the point of view of the newly ordained bhikkhunīs, they would clearly be in an untenable position if they had serious doubts about the validity of their ordination.[ii] Further, since it seems that a large number, perhaps most, existing Theravada bhikkhunīs have been ordained by the same procedure as the one used in Perth, the issues brought up by Ajahn Thanissaro are clearly of great importance.


Given the above, I have read through Ajahn Thanissaro’s argument carefully. My conclusion is that, as his argument stands, he has not shown that a bhikkhunī ordination in which 2 or 3 candidates are ordained simultaneously is invalid. I will now examine Ajahn Thanissaro’s argument, starting with his point 11 where he argues directly from the Canonical Vinaya. I will go through his reasoning step by step.


At sub-point 11a Ajahn Thanissaro says that “This rule (bhikkhunī pācittiya 83) is in force regardless of the number of residences available for bhikkhunīs”. This is the only step in his deductive sequence in point 11 that I agree with without reservations.


Ajahn Thanissaro continues in point 11b by stating that “There are no examples of transaction statements authorized in the Canon where the sheer form of the statement would intrinsically entail breaking a rule”. Actually, on careful consideration, there are several such examples. According to Mv I 70.1-3 a bhikkhu incurs a dukkata for ordaining someone without a bowl and/or robes. The ordination itself, however, seems to be valid, since this section (i.e. Mv I 70) stands in direct contrast to the closely preceding ones at (Mv I 61-68) where the ordination is not valid. The commentary supports this interpretation by stating outright that the ordination is valid.[iii] Now, regardless of whether the ordinand has or doesn’t have a complete set of bowl and/or robes, the saṅghakamma  statement of the ordination invariably states that he/she does (Mv I 76.10). In the case where the candidate does not have a complete set, everyone who partakes in the ordination would know that this is the case (in an earlier part of the ordination procedure (Mv I 76.3) the bowl and robes are pointed out to the candidate), and thus the ordination statement would amount to a conscious lie. Thus, although it is clear that this ordination is valid, the saṅghakamma statement involves a deliberate lie, which of course is a pācittiya offence under pācittiya 1. Since it is known beforehand that the candidate for ordination does not have a bowl and/or robes, this is a case where “the sheer form of the statement would intrinsically entail the breaking of a rule” and, contrary to Ajahn Thanissaro, it would still be valid.[iv] In other words, because Mv I 70 implicitly allows for the ordination of someone without a bowl and/or robes, it also establishes a situation where the procedure intrinsically entails the breaking of a rule.[v]


And this is not the only such case. As I have already mentioned, the same passage at Mv I 70 also states that the bhikkhus involved in ordaining someone without a bowl and/or robes incur a dukkata offence.[vi] Again, the monks involved would be performing a saṅghakamma that intrinsically entails breaking a rule but which nevertheless would be valid. Another example is the declaration in the ordination statement, whether this in fact is true or not, that the candidate is “free from obstructing things”.[vii] Although the ordinand may not be free from these obstructions, and the ordination statement therefore would involve an intentional lie, the ordination is still valid in most instances.[viii]


Ajahn Thanissaro then states, in point 11c, that “Thus the allowance at Mv I 74.3 – allowing a single proclamation to mention two or three candidates for bhikkhu ordination – cannot be extended to bhikkhunis, for such a statement would intrinsically be ‘apart from the Vinaya … apart from the Teacher’s instruction’.” But I have just shown that, given certain types of knowledge about the candidate to be ordained, the form of any ordination statement does intrinsically entail the breaking of a rule, and yet the ordination is valid. Thus it does not follow that such an ordination statement is “apart from the Vinaya”, in the sense this phrase is used at Mv IX 3.2.[ix]


Further, Ajahn Thanissaro’s logic in point 11c hinges on his interpretation of the phrases “apart from the Vinaya” and “apart from the Teacher’s instruction”. He seems to understand these phrases to have a very broad range, where any infringement of the Vinaya potentially would make a saṅghakamma invalid. But as I have already pointed out, it is possible to deviate considerably from the Vinaya, including the breaking of Patimokkha rules, and for a saṅghakamma still to be valid. I would suggest, therefore, that a more congruent understanding of Vinaya here is that it refers to the rules pertaining to the valid performance of saṅghakamma.[x] Alternatively, it might not be unreasonable to follow the commentarial interpretation, which states that “but here Vinaya means admonishment and making remember (i.e. admission).”[xi] Admonishment and admission are preliminary acts in certain types of saṅghakamma, in particular those involving the punishment of someone for especially bad behaviour, but they are not relevant for ordinations. As for the phrase “apart from the Teacher’s instruction”, the commentary explains this as a saṅghakamma where the motion and announcement(s) are not properly performed.[xii] Thus, “apart from the Vinaya” only has a narrow scope in the context of Mv IX 3.2, and there are really no grounds for taking it to include cases where one commits an offence as part of the ordination statement.


In point 11d Ajahn Thanissaro says that “As Mv X 3.2 (sic) states, any transaction using this sort of statement would be ‘not a transaction.’” Presumably, “this sort of statement” refers back to the ordination statement. If that is indeed the case, then Ajahn Thanissaro is misquoting Mv IX 3.2, for this passage contains no direct link between any type of ordination statement[xiii] and the phrase “not a transaction”. What it does contain is a link between “apart from the Vinaya” and “not a transaction”. But, as I have argued above, “apart from the Vinaya” only has a very narrow sense in the context of Mv IX 3.2.


At point 11e Ajahn Thanissaro argues that “there are no exemptions for the ruling at Mv X 3.2 (sic)”. Perhaps this is true. But in light of my argument above it is irrelevant, because no direct causal relationship can be found between the simultaneous ordination of 2 or 3 bhikkhunīs and the ruling that a saṅghakamma is “not a transaction”. It follows that Ajahn Thanissaro’s conclusion, at point 11f, that “the candidates would not count as bhikkhunīs” does not hold.


There is another reason why Ajahn Thanissaro’s argument is weak. The Vinaya is quite clear about the grounds on which any saṅghakamma is invalid, and these do not include the situation where the “form of the statement would intrinsically entail the breaking of a rule”. The sort of factors that are required to make an ordination valid include the following:

·        The candidate to be ordained is present;

·        The candidate is 20 years old or more;[xiv]

·        The candidate is not one of several types of ‘unqualified’ persons, or an animal;

·        The quorum for performing the ordination is complete;

·        The Sangha is united (samagga); that is, all the monks within the sīma are present at the ordination, or they have given their consent;

·        The ordination statement contains exactly one motion (ñatti) and three announcements (kammavācā), in that order;

·        Nobody present speaks out against the ordination;

·        The procedure performed is an ordination, not some other saṅghakamma.

It is only if such requirements – that is, requirements that are specifically mentioned in the Vinaya – are not met that the ordination fails, and only in these cases is the ordination “not a transaction and should not be carried out”. Any supposed ground for failure that falls outside of what is specified in the Vinaya is a matter of personal opinion, and cannot be a universally accepted standard. Since, in my view, Ajahn Thanissaro’s argument is a matter of personal opinion it cannot, and will not, be accepted as universally valid.


In general, according to the Vinaya the following circumstances need to be satisfied for any saṅghakamma to be valid:

“And how, monks, is a (sangha-)kamma united and in accordance with the Dhamma? …[xv] If, monks, concerning a (sangha-)kamma with one motion and three announcements, the motion is established first (and) then the (sangha-)kamma is performed with three announcements; the bhikkhus who should be present are present; consent has been received from those who should give consent; those who are present do not speak against the act – then the (sangha-)kamma is united and in accordance with the Dhamma.” (Mv IX 3.9)

Again, there is nothing here about the validity of saṅghakamma  depending on its being performed without breaking other Vinaya rules, or indeed that it depends on “the sheer form of the statement” not intrinsically entailing the breaking of a rule (see Ajahn Thanissaro’s point 11b).


At this point I would like to return to Ajahn Thanissaro’s point 5 where he declares that “This sort of transaction statement, because it intrinsically entails the breaking of a rule, would thus be totally unauthorized.” The words “totally unauthorized” are unclear and emotionally loaded. It is certainly true that nowhere in the Canonical Vinaya is such an ordination statement explicitly “authorized”, and if this is all Ajahn Thanissaro is saying then I would have to agree with him. But when he goes on to state that this means that the ordination is “apart from the Vinaya … apart from the Teacher’s instruction” and “not a transaction and should not be carried out” he goes too far. As I have already shown, it is quite possible to break a pācittiya rule while performing an ordination and for the ordination to be fully valid.


I have already responded to Ajahn Thanissaro’s point 6 (in my response to his point 11) but to recapitulate: in Mv I 70 there are good reasons to believe that the ordination is valid even though the ordinand does not possess a bowl and/or robes. The ordination ceremony in this case intrinsically entails the breaking of a rule, that is, pācittiya 1. If this argument and the ones above are accepted, then Ajahn Thanissaro’s further discussion in points 7-10 becomes irrelevant since it hinges on what had been established in his points 5 and 6. In particular, it may well be true that not mentioning the upajjhāya in the ordination procedure makes the ordination invalid, but this is beside the point. The lack of an upajjhāya can arguably be considered a breach of the conditions given in the Parivāra,[xvi] but no such breach exists in the case of ordaining 2 or 3 bhikkhunīs at the same time. In contrast to the case where there is no upajjhāya, for which Ajahn Thanissaro’s argument may hold, an ordination of 2 or 3 bhikkhunīs at the same time does not breach any of the stipulations made in the Canonical Vinaya for a valid saṅghakamma . His points 8-10, then, do not add anything to what he has already stated in points 5 and 6.


A final and important point is that bhikkhu pācittiya 65, which concerns the invalid ordination of someone less than 20 years old, specifically states in the rule itself that the ordination is invalid. No such statement is found in bhikkhunī pācittiyas 82 or 83, and thus it is reasonable to assume that the breaching of these rules cannot in itself invalidate the ordination. Even the commentary (Sp IV 945,4-10) does not say anything about the ordination having failed.


To summarize, it is clearly undesirable to perform an ordination while committing an offence, and one should obviously avoid this if at all possible, but it does not void the procedure. I can only conclude that Ajahn Thanissaro has failed to establish what he claims to have established, that is, that “a bhikkhunī ordination in which the transaction statements mentioned more than one candidate per statement would not be considered valid, and the candidate would not count as accepted” (Ajahn Thanissaro’s point 10).


[i] One can perhaps interpret the Vinaya in a compassionate way, but not altogether ignore its statutes. Ajahn Thanissaro doesn’t actually use the word compassion, but employs the term “heartlessly legalistic”.

[ii] Of course, it is the bhikkhunīs themselves who have to decide whether they have serious doubts and their position is untenable.

[iii] Kammaṃ pana na kuppati, “but the (sangha-)kamma does not fail”, (Sp V 1025,23).

[iv] It is clear that not having a bowl and/or robes quite literally means not being the owner or in possession, even temporarily, of such requisites. This is so because the relevant section states that the newly ordained monk would collect alms with his hands and/or walk naked on piṇḍapāta (Mv I 70.1-3). Moreover, the next section (Mv I 70.4-6) concerns a monk who borrows a bowl and/or robes (for the duration of the ordination procedure, says the commentary, Sp V 1025,24) but then collects alms with his hands and/or naked. It follows that in Mv I 70.1-3 the person to be ordained must have been completely without a bowl and/or robes.

[v] In actual practice it may well be that the final ordination statement (Mv I 76) came into being after the rules about ordaining someone without a bowl and/or robes. This would explain the apparent contradiction. However, this sort of argument is difficult to sustain, and we are therefore compelled to use the text as we have it, disregarding any possible historical evolution.

[vi] Or perhaps only the upajjhāya; the Pali just says “whoever should ordain, there is an offence of dukkata”, yo upasampādeyya āpatti dukkatassa.

[vii] Parisuddho antarāyikehi dhammehi, (Mv I 76.10-11).

[viii] For example, if the candidate has not received his parents’ permission (Mv I 54.6), if he has one or more of five types of illness (Mv I 39.7), if he is employed by the king (Mv I 40.4), if he is a criminal (Mv I 41-45), if he has debts (Mv I 46.1), if he is a slave (Mv I 47). In all these instances the ordination is valid. But since the ordination statement always declares that the candidate is free from obstructions, it follows that the sanghakamma reciters would be uttering a deliberate lie.

[ix] Ajahn Thanissaro refers to Mv X 3.2 throughout his letter, when in fact it should be Mv IX 3.2.

[x] Notice that the phrases we are concerned with are both found in a chapter (Mv IX) that deals exclusively with the question of the validity of saṅghakamma.

[xi] Ettha pana vinayoti codanā sāraṇā ca. (Sp V 1146,11)

[xii] Satthusāsananti ñattisampadā anussāvanasampadā. (Sp V 1146,12)

[xiii] Or any other saghakamma statement for that matter.

[xiv] This is so for the ordination of bhikkhus. For the ordination of bhikkhunis the situation is more complex, but in effect there seems to be two distinct minimum ages, 12 and 20.

[xv] The elided text concerns sanghakamma with one motion and one announcement, and this is not relevant for an ordination. In any case, the rules are virtually identical.

[xvi] Whether in fact the absence of an upajjhāya makes the ordination invalid is not entirely clear. It may be that the commentary here is going beyond what can be inferred from the Canonical Vinaya. In any case, this argument does not relate directly to the point I am trying to make. (For the record, Ajahn Thanissaro’s translation of pacchā vā ñattiṃ ṭhapeti as “or if it later sets aside the motion” is incorrect. The phrase actually means “or he establishes (i.e. speaks) the motion afterwards (i.e. after the announcement or kammavācā).”




    - Ven Ayya Tathaaloka Bhikkhuni: Bhikkhuni Preceptor's Response


Pavattini's Response

Regarding Ajahn Thanissaro's Letter on Ordination Validity

First, I would like to express my deep appreciation for the venerable Ajahn Vayama and the nuns of Dhammasara monastery for their inspiration in the rightness of the Dhamma & Discipline of the Buddha, and their tremendous bravery, courage and devotion in undertaking Theravada bhikkhuni ordination.
I would also like to mention my great appreciation for the extensive works of the Ven Thanissaro Bhikkhu in the fields of Dhamma and Vinaya to which he has greatly contributed.  His work with the Buddhist Monastic Code I inspired and often assisted me through years of comparative bhikkhuni Vinaya studies.  In addition, i have learned much from my consultation with Ajahn Thanissaro over the years, and he has always been generous, without fault, in his sharing of his Dhamma & Vinaya knowledge.  
As with most other Vinaya scholars and practitioners that i know, i have not always agreed with Ajahn Thanissaro's conclusions in his scholarship, and he himself has rightly edited and republished his Buddhist Monastic Code as he has considered, and reconsidered and learned more about the subject through peer critiques, reflection and further research. This is a normal, ongoing process in scholarship as we study these ancient Pali texts and work with translating them into good, modern English. 
I have had the chance to speak with Ajahn Thanissaro personally about his review of the method of the bhikkhuni ordinations in Perth at Bodhinyana Monastery, as well as to carefully review his letter.  Ajahn Thanissaro writes with an authoritative style and makes a proposal, using an previously unheard of combination of Vinaya and Commentarial quotations and opinions, tied together by a thin line of tentative inference, prefaced and followed by a conclusion which he proposes to the reader.  If i were not familiar with the texts and with Ajahn Thanissaro's personality, i might not realize that his letter is not an incontrovertable statement of absolute law.  But i am familiar with the text, and know that it is not.  To my careful reading rather, based upon my knowledge of Vinaya, i understand the line of inference that is drawn to be stretching reason and tentatitive to the point of being untenable.  
Simply, neither the Pali Vinaya text involved nor the Commentaries themselves mention anywhere that ordinations, conducted under the circumstances that Ajahn Thanissaro brought into question, are invalid.  
Ven Bhikkhu Bodhi, Ven Ajahn Brahm and Ajahn Brahmali all make the basic points involved well with proper references, so i will not go into that here.  Ven Bhikkhuni Sudhamma makes further points, unravelling the entire web of inference in each of its parts.  Furthermore, fellow scholars of other renditions of the Vinaya confirm that the Pali text is not alone in its texts making no mention of such invalidity; but rather that other Vinaya texts also, related to the specific precepts in question, do not state the ordinations invalid.  
I would like to mention that i do not write this simply as a matter of proposing a similarly inferential or theoretical counter-argument.  Nor do i simply *want* the ordinations to be valid, or to cover a mistake in proceeding wrongly.  If a reasonable argument for the invalidity of the ordinations had been put forth, the new bhikkhunis were ready to reordain.  The Preceptor (myself) and the ordaining Acaryas would have supported that this happen, with the flaw being corrected.  This is very possible and there was such ready willingness, in the case an invalidating flaw was found.  
The questions about ordaining Theravadan bhikkhunis have been being researched energetically for several decades now, with an increase in such scholarship in the past 20 and especially the past 15 years, with a great increase in understanding coming from the large gathering of lay and monastic Buddhist scholars at the First International Congress on Buddhist Women in Hamburg in 2007. (We missed Ajahn Thanissaro in Hamburg.) Essentially non-different methods of ordination for bhikkhunis had already been researched and determined by Sri Lankan monastic and lay scholars, and hundreds of women fully ordained in Theravada traditions by these means in Sri Lanka for nearly the past decade.
The methodology used in the ordination of the four new bhikkhunis in the sima at Bodhinyana Monastery was much reviewed and discussed by both monastic and lay scholars in the years prior to and since the Hamburg Congress, and reviewed in great detail by monastics, both bhikkhus and bhikkhunis, in the months before the ordinations.  As is the tradition at Bodhinyana Monastery, the ordinations were conducted with rigor in care and attention to detail with regard for their flawlessness. 
I must be clear that as 
Pavattini or Preceptor, i undertook a confessable offence in Pali-text Vinaya by ordaining more than one woman every other year.  According to Vinaya, this offence is not shared with those who are ordained; it is my own.  In this case, according to Vinaya, their ordination is rightful, pure and flawless - visuddha


Also according to Vinaya, after confession of all confessable offences in the presence of a fellow monastic, a bhikkhu or bhikkhuni does not continue to remain "in offence;" but rather through the Parisuddhi Uposatha, the "declaration of purity" on our lunar observance days, according to Vinaya, s/he must affirm and reaffirm themselves as once again parisuddhi, that is, completely pure. It is a deep training in letting go and going beyond.  Of course this does not mean that we should be lax.  I myself regularly try to be scrupulous about even the smallest of points given for training in this discipline.  
In Vinaya, the precepts themselves contain both their letter and their intent. Vinaya is not a rule without logic or reason. The intent often becomes apparent through the origin stories and explication, if not so in the precept itself.  In the case of the precepts involved here --Bhikkhuni Pacittiyas 82 & 83 -- the origin stories mention the intent as being to protect and prevent more bhikkhunis being ordained than there are lodgings for (which had caused lay supporters to complain).  In this specific contemporary case, i would like to affirm that the bhikkhunis already have plentiful lodgings in their already established and well-supported forest monastery.  And their lay supporters of the BSWA (Buddhist Society of Western Australia) were unanimously supportive of their being fully ordained.  Additonally, the precepts themselves would protect more bhikkhunis being ordained at once than can be educated and instructed in Dhamma and the monastic Discipline.  In this case, due to the slow process of Theravada bhikkhuni ordination, Ajahn Vayama, already an accomplished and highly regarded Dhamma teacher for years, had already been training as a samaneri (female novice) for more than 25 years before her full ordination. (Vinaya only requires 2 Vassas of basic training for bhikkhunis.) The three additional women ordained had been accepted as novices and trained one by one over the past eight years.  The juniormost of them had already been in training for four years.  
Additionally, being associated with highly regarded meditation teacher Ajahn Brahm and living nearby his monastery, the Dhammasara nuns have had and will have excellent opportunity for meditation instruction under his tutelage.  As both Ajahn Brahm and other monks of his monastery such as Ajahn Brahmali are also excellent Vinaya scholars, additionally, these new bhikkhunis have had and will have some of the best Vinaya instruction available to bhikkhunis anywhere in the world.  These are exceptionally excellent circumstances in monastic life for higher training in
sila, samadhi and panna
, in which the factors that the precepts are protecting bhikkhunis from lack of are available in full and blessed abundance.  Additionally, in terms of education in Vinaya from these knowledgeable bhikkhus, and for the sake of fully keeping the precepts and practices being learnt that they might be fully practiced, it is desirable and more greatly facilitous for there to be a Bhikkhuni Sangha together, rather than just one individual bhikkhuni. And bhikkhu teachers, in Vinaya, do not have the same restriction on the number of pupils that they may instruct as bhikkhunis do.  In addition, Vinaya most certainly allows for knowledgable bhikkhus to give bhikkhunis teachings in Dhamma and Vinaya when called for.  Vinaya also allows for a bhikkhuni teacher to provide for her students' instruction either herself, or by providing for another qualified teacher, which has well been done in this case.  In fact, it was the qualified teacher who provided for a Bhikkhuni Preceptor, which is not at all without precedant.  All of these points of Vinaya together describe the new bhikkhunis training circumstances.
These paragraphs above are my own reasoned inferential argument regarding my own commital of an offence by the letter but not by the spirit of Vinaya, which others are welcome to confer with me about.  Such welcome conference nonwithstanding, these factors above are in accordance with the explicitly stated intention and letter of many of the other precepts, which combined make up the discipline of the Bhikkhuni Patimokkha.  And, with regards to the two precepts taken issue with, choosing the intention above the letter where they diverge in this case, does not, in either the Vinaya or the Commentaries, invalidate an ordination.
Again, with regards to both the specific references and the spirit of Vinaya, i am in agreement with the Responses by Ven Bhikkhu Bodhi, Ven Ajahn Brahm and Ven Ajahn Brahmali. 
With regards to the letters and words of Vinaya-dhamma, i am in especial agreement with one felicitious reference by the venerable Ajahn Thanissaro also emphasized by Ven Bhikkhuni Sudhamma, which is worthy of repeating many times.  
For here, the Blessed One begs the monks of Kosambi, who were then quarrelling with one another: 


Open your hearts and let your light shine forth;

become forebearing and gentle. 



Enough, monks;

no strife,

no quarrels, no disputing.

Of course, as with so many of the noble teachings of the blessed Buddha, this too is for monks, but not for monks only; for monastics, but including all good men and women.


May all of our efforts as a Sangha in this time be dedicated to the purification of underlying defilements from our heart, to clarification and rectification of our monastic livelihood, and to our long lasting peace and happiness through the causes and attainment of Nibbana.
Tathaaloka Bhikkhuni, Pavattini

26 November 2009





Ven Sudhamma Bhikkhuni: A Bhikkhuni's Response to Ven Thanissaro's Theory


Response to Ven. Thanissaro's letter of November 13, 2009

A challenge has arisen to the validity under the Vinaya of the October 22, 2009 ordination of four bhikkhunis in Perth, Australia, organized by their teacher, the well-known Dhamma lecturer and Vinaya master Ven. Ajahn Brahmavamso.   Ven. Thanissaro Bhikkhu of Metta Forest Monastery, well-known Vinaya scholar, author and translator of Dhamma books, and author of the Buddhist Monastic Code, was asked by detractors of the ordination to examine the ordination procedure's script.  He cooperatively did so and offered a lengthy analysis of the only error he perceived, concluding with seeming reluctance that the ordinations were invalid; his report was shared in a letter dated November 13, 2009 (published online at
The well-known abilities of our highly respected elder Venerable Thanissaro, including his knowledge of Vinaya and related commentarial material, may cause some readers to accept his conclusion without reflection.  However, key points of his letter are not spelled out in the Vinaya.  Understand, therefore, that the Venerable Elder's opinion is not straight "black letter law" Vinaya.  He put together a creative theory; his letter is more like a newspaper's editorial than straight news.  We can accept or reject his interpretation based on the soundness of the reasoning used.  
Following is my detailed analysis of the reasoning used.  I offer this document with awareness of seniority and status of the great Elder, and with fear that some of my words may be taken as disrespectful; if so, may I please be forgiven.  With humble respect, I offer this response for consideration in hopes of helping towards an eventual peaceful welcome –particularly by him and other notably conscientious elders– of the female gender in robes.  The unambiguous help and support of such elders would be tremendously beneficial to the practice of the path of a very large number of women.

PART ONE: Was There a Flaw?
The flaw that the Venerable Elder perceived involved the implications of a Pacittiya (Confessable) rule for bhikkhuni preceptors, which caused him to determine that the form of the "transaction statement" used in the ordination shouldn't apply to bhikkhunis. His argument rests on a premise that we cannot ascribe to bhikkhunis an allowance given to bhikkhus to ordain multiple candidates at one time with shared proclamations, as no specific wording grants to bhikkhunis this convenience.  
Here we must digress to consider why questions may arise as to what protocols bhikkhunis may follow.  While it would be convenient for a modern bhikkhuni to have a separately laid out comprehensive document entitled Bhikkhuni Vinaya, one that lacks reference to the male monks' protocols and rules, that is not what we have inherited.  In trying to create or re-create such a document, we should not jump to any conclusions hastily.  We inherited the one set of Vinaya books that primarily focus on bhikkhus and contain special portions in which some differing rules and procedures for bhikkhunis were noted.  Much of this hefty material is clearly to be shared by both genders, some of it is obviously not, and some may be a little unclear, despite the help of Commentaries.  To understand how bhikkhunis can make sense of all this material, we rely upon the Buddha's advice that the bhikkhunis should train as the bhikkhus do regarding rules held in common: unless otherwise noted, bhikkhunis generally follow the same procedures and protocols given to bhikkhus. (CV. 10.4)  Where conflicts seem to arise between text otherwise applicable to both genders and what is thought to be accepted (or not) for bhikkhunis, we bhikkhunis rely heavily upon our common sense.  (That is, we apply simple logic, tempered by bearing in mind the entirety of one's learning of Dhamma and Vinaya, with full mindfulness of its underlying trends and principles, as well as the general standards or trends in its application.)

Returning to the convenient allowance that the Venerable Elder would deny bhikkhunis, he wrote:

2) Mv.I.74.3 places a special condition on applying this principle [of allowing multiple people to be handled in one transaction] to the Acceptance (full ordination) of bhikkhus: “I allow a single proclamation to be made for two or three if they have the same preceptor, but not if they have different preceptors.” (emphasis added)
Yet much of bhikkhuni protocol comes from instructions given to bhikkhus, also with no special mention directing them towards bhikkhunis; why should this allowance be any different?  The Venerable Elder sees a reason why this allowance cannot belong to bhikkhunis.  He reasons that because a female preceptor (pavattini) is not supposed to have multiple students in one year, this single-proclamation allowance for multiple students never applied to bhikkhunis. The crux of his argument is that we can't ascribe to our (re-created) Bhikkhuni Vinaya an allowance (letting multiple students ordain by shared proclamation) which would never come up unless the bhikkhuni preceptor were to break a Bhikkhuni Pacittiya rule (No. 83 against ordaining multiple students in one year). 
He then further proposed, again going into uncharted waters with this second theory, that if they make a single proclamation despite clear lacking permission to do so, it must invalidate the ordination.  The four bhikkhunis recently ordained in Perth shared one bhikkhuni preceptor, Ven. Ayya Tathaaloka of the USA, and at the end of the ceremony their proclamations were made in pairs.  For this, he calls the otherwise flawless ordination invalid.  (Let those sympathetic to nuns please set aside any feelings of moral outrage at the idea of rejecting these excellent nuns' long awaited and hard-gained entry to fully living the holy life, due to a petty legal technicality, and examine this issue with dispassion.) 
His two theories –that there was a flaw and that such a flaw would be fatal– assume some unproven factors.  Most surprisingly, he assumes that the allowance was predated by Pacittiya rule No. 83 (the rule against bhikkhuni preceptors ordaining multiple students in one year).  We have no reason to believe it so.  In fact, it makes more sense to assume that the bhikkhuni preceptors' restriction came later, at a time when the female Order was flourishing beyond its means. 

Common sense suggests that this allowance was intended for any co-students (see discussion of origin of the allowance, below) whether pupils of bhikkhus or bhikkhunis, for nothing stood in the way of the female gender following it, until Pacittiya 83 was set down.  Nothing special about the bhikkhuni ordination script suggests that the questioned allowance shouldn't apply; the bhikkhu and bhikkhuni ordination scripts are essentially identical, differing only by slightly different qualification questions and the bhikkhunis' additional part of going to the male Sangha to repeat the motion.  (The ordination procedures are spelled out in detail at Cv.X.17 for bhikkhunis and Mv.I.76 for bhikkhus.)  The allowance appears in the scripture alongside with other allowances to bhikkhus obviously available to bhikkhunis; for example, the statement directly before it is allows a polite way to state the name of the preceptor during an ordination; the one directly after it allows how to calculate a candidate's age (counting from the time of conception instead of birth, another practical instruction which bhikkhunis should follow).   
Perhaps many bhikkhunis availed themselves of the allowance before the mentoring restriction came down; why not?  In fact, the scriptures tell of large numbers of bhikkhus or bhikkhunis who ordained together and trained together under a bhikkhu or bhikkhuni teacher, such as "Patacara's Five Hundred" ("Pancatasata Patacara") who went forth together under Bhikkhuni Patacara Theri (see Thig 127-132 and related Commentary).  Thus we can surely ascribe to the bhikkhunis an allowance that they simply ceased to avail themselves of later (due to Pac. 83).  The flimsiness of the Venerable Elder's theory has been revealed.  The assumption that the bhikkhunis' Vinaya never included this allowance is untenable.  It would be wrong to criticize a bhikkhuni ordination for making use of it when the occasion arose.
~ Although the point has been made, for the sake of education let's continue to pull apart all of the letter's reasoning, step-by-step. ~
A bhikkhu ordination ceremony culminates in a motion and three proclamations identifying the candidate and his preceptor, and asserting that the candidate seeks ordination and is qualified; if all remain silent, the proclamations become the decision of the group, and the ordination is a completed legal transaction.  Permission came for lumping together proclamations for multiple candidates, when two men planning to ordain under one preceptor quarreled over whose proclamations would be spoken first (Mv.I.74.2). Being first presumably would determine not only who felt more favored but which student would become the more senior of the two, a matter greatly impacting the co-students' daily lives. The Buddha brought peace by letting the two mens' ordination proclamations be combined, apparently to let them enjoy equality together as co-students. He stated, "I allow you, monks, to make two proclamations together." (Later he allowed up to three.  Mv.I.74.2).
This allowance was not an essential ingredient in ordinations, but simply a convenient procedural strategy for smoothing away potential quarrels of power-struggles or jealousy; it may also serve to save time, particularly when large numbers ordain.  The Buddha later chose not to extend the joint procedure to cases of multiple preceptors, and hence amended it by adding, "but not if there are different preceptors."  (Mv.I.74.3).   
The odd description by the Venerable Elder of this rule being a "special exemption" to a "principle" of transaction statements gives the erroneous impression that the Buddha made this rule in order to set ordinations apart from other examples in which Community transactions involving multiple people can be bundled together.  His wording also creates the impression that this rule carries more weight than it does.  The Buddha wasn't trying to specially protect transaction statements when he originally formulated the rule, but to protect the untrained people's egos.   
At Point (4) in his letter, our Venerable Elder sketches out an obstacle to the natural assumption that the convenient quarrel-preventing allowance would have been ascribed to bhikkhunis as well as to bhikkhus.  He introduces the interesting idea that we must fill in blank areas of Bhikkhuni Vinaya by using the Great Standards (a moral analysis comparing what is desired with what already is or isn't allowable, to determine whether it
should be allowed).  The Great Standards can be part of our common sense approach to questions of filling in Bhikkhuni Vinaya, but cannot displace common sense. For example, one time Ananda expressed concern that in an upcoming ordination he would be expected to name a preceptor who happened to be his own teacher.  (He felt embarrassed because calling one's own teacher by name would be rude.)  The Buddha responded with an allowance for bhikkhus to identify preceptors by clan name rather than personal name (Mv.I.74.1).  In that case, common sense says that bhikkhunis, too, may make use of the allowance to be polite, without need to resort to a moral analysis using the Great Standards.  (This will become relevant because of the Venerable Elder's subsequent assertion that the Great Standards cannot be used as a way to give bhikkhunis the joint proclamation allowance, due to the moral glitch of a rule being broken.)

Point (4) of the letter also introduces the reader to the Bhikkhuni Pacittiya rules 82 and 83, which together limit the numbers of students a female preceptor can ordain to merely one every other year.  Why did the Buddha set down this limitation?  The scripture mentions the nuns' crowded housing, but Ven. Thanissaro adds a convincing point that this rule for bhikkhuni preceptors gave each new bhikkhuni the full attention of her preceptor during the brief two years of her training period.  In other words, the Buddha set down this rule, like so many other rules, because he wanted ordained women to thrive.  
Nowadays, however, Bhikkhuni Pacittiya No. 83 can pose an impediment actually preventing the newly re-emerging Theravada Bhikkhuni Order from thriving.  At this fragile point in the Theravada bhikkhunis' revival while we have very few qualified preceptors, this rule, though set down to benefit the Bhikkhuni Order, could instead strangle it.  For this reason, the rule was deliberately ignored during the October 22, 2009 ordination.  (Don't worry, the newly ordained bhikkhunis will not end up neglected, but will continue to receive good training by their venerable teacher Ajahn Brahm and the senior bhikkhu teachers of his monastery who he has provided for to instruct the bhikkhunis.)  We hope in future, once we have gotten beyond these pioneering days for Theravada bhikkhunis, to enjoy a large, thriving Order with many available bhikkhuni preceptors, and with Pacittiya No. 83 being properly observed once again.  (If the Theravada Bhikkhuni Order fails, then whole package of bhikkhuni training and livelihood as understood in Theravada Buddhism falls back into disuse, a vastly greater harm than temporarily setting aside one little training rule intended to help bhikkhunis.)
Our Venerable Elder's application of Great Standards brings him to conclude that the expected violation of a Pacittiya rule would morally obstruct us from ascribing to bhikkhunis the availability of the allowance. If guided by common sense, however, the Great Standards would cause us to conclude that the preceptor's status could not prevent any co-students from benefiting from the peace-keeping allowance.  Maybe female candidates "shouldn't" be co-students, but when they sometimes are, this allowance belongs to them.  (Unless anyone wishes to make the case that women seeking higher ordination are so superior that the Buddha would not expect them to quarrel over something so foolish as who gets seniority.)  Nor is the Kammavacacarini (Advocate) prevented from making simultaneous proclamations during the ordination ceremony, to bring peace to a preceptor's students or for some other good reason. Thus we have ample reason to believe that if bhikkhuni preceptors were to ordain multiple students the debated allowance would be available to her students. 
Given this, and indications that large numbers of bhikkhunis made use of the allowance prior to Pacittiya 83, we can safely conclude that when the need arises, bhikkhunis can make use of the allowance.  Thus the October 22, 2009 ordination ceremony had no known flaw. 

PART TWO: Would A Flaw Invalidate an Ordination?
Although we have seen that there was no flaw, let us ask what a flaw would mean.
First let us get clear on what the Venerable Elder is not trying to claim, by setting aside a simplistic argument not under discussion.  A bhikkhuni preceptor who sponsors multiple nuns would incur a Pacittya offense, which means that it would be naughty for her to do so –she should indeed hesitate– and that she would need to later confess her offense to another bhikkhuni.  It does not mean that she harms the ordination by stepping into that role, nor is the Venerable Elder trying to say that she does.  Even if the bhikkhuni preceptor were a parajika (defeated one) or a matricide / parricide, her participation would not undermine the candidate's ordination (Mv.I.69.4); hence her status as a Pacittiya-breaker (which is not such a big deal) should pose no harm.  The Venerable Elder does not try to claim that it would, for he is attempting to make a more subtle argument.
In Point (5) of the letter, the Venerable Elder apparently made up a new general principle of monastic protocol when he stated, 
"This sort of transaction statement, because it intrinsically entails the breaking of a rule, would thus be totally unauthorized." (emphasis added.) 
This must be his unique idea, for does he not next inform us, two sentences later (in Point (6)), that there are no examples of this in the Canon?  If the situation is unprecedented, then from where did he get this mightily impressive non-authorization formula?  He wrote,
 "6) It bears noting that there are no examples of transaction statements authorized in the Canon where the sheer form of the statement would intrinsically entail the breaking of a rule."  (emphasis added)   
(This wording, that the "sheer form of the statement would intrinsically entail..." makes it sound very important.  Yet, rule Pac. 83 is not broken by the form of the transaction statement.  If multiple candidates ordain under one female preceptor, the little rule is broken, regardless of the use or non-use of a single transaction statement; these two issues are unrelated.  Whether to do a single statement is a separate question that depends on the needs of the candidates.  The Point (6) assertion is sheer hyperbole.)  

In Point (7), our Venerable Elder asserted that flawed transaction statements generally invalidate legal acts.  (Legalese wording alert: "generally" means not-in-all-cases.  Hence he has just stated that flawed transaction statements do not always invalidate legal acts!)  Therefore, he continued, this principle applies to ordination transaction statements; and hence if flawed, the ordination becomes invalid.  But this is simply another theory. 
Dozens of much more substantial ordination flaws were declared by the Buddha to be mere "wrong-doings" that do not invalidate the ordination or cause the candidate to be expelled.  Even the act of –for examples– ordaining a candidate lacking a preceptor or who takes the entire Order as his preceptor (two examples mentioned in the letter) (Mv.I.69.1-2); or who has a matricide or parricide as a preceptor (Mv.I.69.4), or who is severely crippled (Mv.I.71.1), or has a dreaded communicable disease (Mv.I.39.7), would be considered a mere wrong-doing that is not fatal to ordained status, despite the potential long-term negative impact upon the Sangha.  
The supposed error of a bhikkhunis' students' names being proclaimed together (rather than sequentially) rather pales by comparison to these mistakes.  Someone's opinion that this minor error would invalidate an ordination does not substitute for a solid argument.  As of the end of Point (7), ordinations being rendered invalid by simultaneous proclamations has not been proven.
Returning briefly to Point (5), we find a most fascinating comment: 
"In the words of Mv.X.3.2, it [the supposedly unauthorized transaction of shared proclamations] would be "apart from the Vinaya...apart from the Teacher's instruction.  As Mv.X.3.2 further states, any transaction of this sort is "not a transaction and should not be carried out."
This statement fascinates not because it seems almost bombastic, but because of the citation given, Mv.X.3.2 (the Mahavagga section of the Khandhaka portion of the Vinaya, Chapter Ten, Section 3, paragraph 2), a location immediately recognizable to anyone well familiar with the Vinaya.  This citation does not give us the quoted words. (And I did not manage to track them down.)  Rather, what we find at Chapter Ten is the account of the infamous bad behavior of the monks of Kosambi.  At the cited section and paragraph, we find the Buddha begging these quarrelsome bhikkhus to cease their angry words and open their hearts by letting their "light shine forth" and becoming forbearing and gentle.  He pleads, "Enough, monks; no strife, no quarrels, no contention, no disputing."  But when the monks repeatedly tell him to mind his own business, the Buddha thinks: "These foolish men are as though infatuate; it is not easy to persuade them," and he leaves.  Then he proclaims verses that begin, "When many voices shout at once / None considers himself a fool; / Though the Sangha is being split / None thinks himself to be at fault."  The Buddha continues, speaking verses that would become among the most beloved words in the Canon, including, "Hatreds never cease through hatred in this world;/ Through non-hatred alone they cease; / This is an eternal law."   
Thus does Ven. Thanissaro gently offer some beautiful subtle advice relevant to this very situation, in which the Buddhist world watches with dismay the clamor arisen among senior bhikkhus in the wake of the recent ordination of bhikkhunis into their lineage.  Perhaps his reference will encourage these venerables to reflect upon their behavior, lest more Kosambi-like righteous divisiveness lead to their own harm and the non-benefit of many increasingly disillusioned devotees, for a long time.  (Or, maybe it was just a slip.)

~ The rest of the letter's arguments depend upon hypotheses that we have already dismissed, so need not be addressed further, except for one more that may need clarification~

Point (9) attempts to prove that naming bhikkhuni candidates together in one transaction statement instead of individually invalidates the ordination because the transaction “doesn't touch on the individual.” Failure to touch upon the individual is reportedly one of a short list of reasons that a Community transaction may be deemed invalid; proper individual naming is said to be required for being properly touched upon. 
The argument here would have us accept the far-fetched idea that male candidates named together in a joint proclamation are "touched upon" whereas females are not, simply due to a rule for bhikkuni preceptors (Bhi.Pac. No. 83) unrelated to ordination procedures of proclaiming and naming.  Nothing is lost from the ceremony by naming people jointly, as demonstrated by male candidates' free use of the allowance. Here the argument has overreached, to the point of sillyness.  How can a mere technical lack of permission to do what would normally be permissable for others be called a fatal flaw in an ordination?  Obviously, it must be a trivial, harmless breach, if a breach at all.  
Nonethess, to be absolutely clear on this point, we can affirm that in the October 22, 2009 ordination in question, each ordinee was indeed literally, individually "touched upon" during the ordination ceremony, both physically and verbally.  Her ordained name was pronounced to her, and her bowl and each of her five robes were physically touched on her body by her pavattini together with the naming.  The preceptor (pavattini) Ven. Tathaaloka Bhikkhuni affirmed this by email (Nov. 22, 2009), writing, "Actually, as part of the ordination proceedure, i, as pavattini, noted (named) each individual (and her requisites) individually. i physically touched the bowl and each of the five robes of each candidate, one by one, after naming her and while naming her requisites.  this was part of my part of the ordination kammavaca."   
Ven. Sobhana Bhikkhuni of the Bhavana Society in West Virginia, USA, who acted as the second Kammavacacarini (a kind of an Advocate) for the candidates during the ordination, offers a brief comment: 
"Examining [in the Vinaya] the entire section on ordination, one can see that only a few specific faults are said to invalidate an ordination.  Many other mistakes are said to merely be faults of the preceptor. It must be considered as the great standard that ordinations cannot be invalidated for minor faults.  The Buddha must have foreseen the danger of broken ordination lineages undermining the entire sangha."

PART THREE: Conclusion 
The ceremony was not flawed by a lack of permission to make joint proclamations, as claimed.  Bhikkhunis received this allowance long ago, and simply stopped using it when a new rule, Pacittiya 83, made it irrelevant.  Even if the ordination had been flawed that way, it would go against the norm to invalidate ordinations based on such a minor issue, and its harmlessness is highlighted by the fact that joint proclamations are acceptable in other ordinations. 
The opinion that the October 22, 2009 bhikkhuni ordination was invalid does not withstand reasonable scrutiny.  The ordination was a valid legal act of Sangha; later criticisms or efforts by Sangha members to reopen a valid legal act should be dealt with according to Vinaya rule.

Ven. Thanissaro once wrote, 

"[N]ow that Buddhism is coming to the West, I feel it is time to stop and take stock of the tradition and to check the later traditions against the earliest sources.  This is especially important in a way of thought and life that, from the very beginning, has appealed to reason and investigation rather than blindly accepted authority.  In doing this, I am simply following a pattern that has repeated itself through the history of the Theravadin tradition: that of returning to the original principles whenever the religion reaches an historic turning point." (BMC I p. 16)
The October 22, 2009 ordination of four women into the reluctant Ajahn Chah lineage and the explosion of reaction and debate that swiftly followed from around the world suggest that an historic turning point has been reached in Theravadin Buddhism.  The continued resistance to womens' ordination may be the one of the worst cases we have ever seen in Buddhism of abandoning "reason and investigation" to "blindly follow accepted authority" of dubious origins.  Making recourse to the "earliest sources" to which (according to Ven. Thanissaro's words) we should now turn, what do they show us, particularly when compared to current trends?
We find, on investigation, that the Buddha followed a principle of working hard to ensure women receive the best conditions for success in the holy life, from ease of ordination, to high quality mentoring, to staying focused.  (But what about his oft-mentioned hesitation to ordain women in the first place?  He hesitated only until the right reason was presented: not for the sake of his personal relation with his aunt/foster mother, but for the sake of womens' enlightenment.)  The Buddha readily changed ordination procedures whenever obstacles for women arose:  When shy female candidates were unable to answer questions posed by bhikkhus prior to ordination, the Buddha compassionately intervened by instituting procedures for bhikkhunis to do the questioning, giving rise to the practice of dual ordination (Cv.X.17.1.2).  When a former courtesan tried to fully ordain, but depraved men wanting to abduct her obstructed her from going to meet with the Bhikkhu Sangha, the Buddha made a dramatic change to Community transaction principles to accommodate her need, allowing female candidates to be ordained without actually presenting themselves to the Bhikkhu Sangha for the dual ordination, in times of danger (Cv.X.22).  Such flexible effort to make bhikkhuni ordinations more accessible, when needed, is the original principle demonstrated by the Buddha.

The Buddha's hard work for bhikkhunis did not stop there.  He set down numerous rules to protect bhikkhunis from all kinds of dangers (the travel rule, no talking alone with men, etc.), from distractions (no picture galleries, etc.), and from being taken advantage of by bhikkhus (no carding wool, etc.) or householders (no doing household work for them).  According to Ven. Thanissaro's letter, as mentioned previously, the Buddha limited the number of students bhikkhuni preceptors could ordain in order to make sure the new bhikkhunis received good mentoring.  He forced bhikkhus to help the bhikkhunis in various ways, even requiring reluctant elder bhikkhus enjoying forest seclusion to meet with the Bhikkhuni Sangha to give them needed Dhamma talks (
) (Cv.X.9.5). 
Contrary to the usual requirement to stay put during Vassa, the Buddha encouraged bhikkhus to leave their Vassa residence to assist other members of Sangha –including the women.  He stated specifically that a bhikkhu should go to help a bhikkhuni or female novice if, for examples, she is ill, she suffers from dissatisfaction with the holy life, she suffers remorse, or she has gotten into trouble and needs rehabilitation or an advocate; in such cases, the Buddha said, with the thought of being of help, "you should go, monks, even if not sent for, all the more if sent for".  If a bhikkhuni candidate wishes to be ordained during Vassa, the Buddha said, and she sends a messenger to monks saying that she wishes them to come, then "you should go, monks, even if not sent for, all the more if sent for," with the intention of participating in the ordination
. (The same is true if a novice nun wishes to start the training towards ordination.) (Mv.III.6.12-29).
Listen to how the Buddha described bhikkhunis: "[A] bhikkhuni is auspicious, a bhikkhuni is the essential, a bhikkhuni is a learner, a bhikkhuni is an adept, a bhikkhuni is ordained by both complete Orders by means of a (formal) act at which the motion is put and followed by three proclamations, irreversible and fit to stand
." (Vin iv 213 (emphasis added).)  There can be no doubt as to original principals regarding women entering and finding support in the holy life.
Yet despite all the evidence, some people still believe, perhaps due to blindly following more recent authorities, that obstructing women from the fullness of the holy life that he established for them does the will of the Buddha. Some greatly beloved elders even resort to disingenuous picky legalistic arguments to keep women bound to household life, with all its sorrows and dangers to life and virtue, its heat and constant distractions, and its lack of virtuous companions; a poor vehicle for inner development leading to freedom.  Many devout virtuous women have died with their longing to live the holy life unfulfilled, and this continues, even though most Vinaya experts acknowledge that ordaining women as bhikkhunis is correct within the Vinaya.  This is how current tradition compares with original principals.  
Oh when will all of our beloved and respected elder venerable bhikkhus work so tirelessly as the Buddha to help women everywhere ordain, and use their great authority and enormous skills to encourage, protect, and help their sincere Dhamma sisters to succeed in their wish for liberation?

Bhikkhuni Path