Quoting%20commentary for Chullin 133:27

מיניה הוא דקא משתרו כלים

I say that [those found in] cisterns, ditches and caverns, are free from all restriction because the water therein is as it were, enclosed as in vessels, whereas [those found in] gutters and trenches are under the restriction since the water thereof can in no wise be regarded as enclosed in vessels.

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