Commentary written by Samuel David Luzzatto (known by the acronym Shadal) in 19th-century Italy. Shadal’s commentary develops a unique approach to resolving conflicts between the pshat (contextual) meaning of the text and the practical implications as presented in midrash halakha. Shadal argues that the pshat reflects what the Torah means and the midrash reflects the halakha, not biblical interpretation. He claims that instead of being biblical interpretation, the midrash halakha is rabbinic legislation with the desire to take a more lenient position than the Torah text.