Fulfilling the Chiyuv of Kiddush in Davening
7. The leading poskim argued whether one fulfills his chiyuv deoraisa of Kiddush when saying “ויכולו כו'” in davening (מ''ב סי' רע''א סק''ב וביאה''ל ד''ה מיד). Some hold that one is yotzei Kiddush deoraisa in davening (מג''א שם סק''א, שו''ע הרב ס"ב); others hold that one can only be yotzei the chiyuv of Kiddush deoraisa by making it over a cup of wine (מנ''ח מצוה ל''א). This has several halachic ramifications, as will be explained.
8. In practice, many poskim hold that since Chazal decreed that Kiddush should be said over wine at the place of the seudah, it is as if we have specific intent to only be yotzei the chiyuv of tefillah and not the chiyuv of Kiddush in davening (שש''כ ח''ג פמ''ז הע' ט''ז) so that we are yotzei in the best way according to Chazal, over a cup of wine (מ''ב סק''א, חת''ס סי' ט''ו וי''ז).
9. Safeik. If someone davened but is unsure if he made Kiddush, he would not need to make Kiddush again according to the Magen Avrohom quoted above due to the rule of “safeik derabanan lehakeil” (פמ''ג). According to the Minchas Chinuch however, it is a safeik deoraisa and he would need to make Kiddush again.
10. Someone who davened being motzi someone who didn’t. However, someone who already davened can be motzi someone who did not since his primary intent is to be motzi him in his chiyuv of Kiddush whether it is deoraisa or derabanan (שו''ת שבט הלוי ח''א סי' נ''ד).
