Reference for Chullin 111:43

סיפא אתאן לעוף של מים הואיל ואין לו קרום

He [R'Hana] remarked: But Levi has taught: The defects enumerated by the Sages in the case of cattle equally apply to birds; there is, however, this addition in the case of birds, namely: If the bone of the skull was broken even though the membrane of the brain has not been pierced! - He replied: That [defect] refers only to a water bird for it has no membrane.'

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