Reference for Chullin 280:45

רובצת ולא מעופפת יכול אפי' כנפיה נוגעות בקן

Now presumably the expression 'upon them' bears the same meaning as 'among them', and just as 'among them' means that she is actually touching them so 'upon them' also means that she is actually touching them; it follows, however, that if she was upon the branches of a tree, one is not bound [to let her go]!<span class="x" onmousemove="('comment',' Since she does not actually touch them; contrary to Rab Judah's ruling.');">¹⁹</span>

Rashi on Deuteronomy

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