Responsa for Eruvin 46:1
רבי עקיבא היינו תנא קמא
Is not R'Akiba [laying down] the same ruling as the first Tanna?<span class="x" onmousemove="('comment',' The Rabbis, who (supra 18a ab init.) contended that it is permissible to move objects in a garden and the like (which were not enclosed for dwelling purposes) if the area is not more than two beth se'ah i.e., about seventy and two-thirds cubits square (Rashi) .');"><sup>1</sup></span> The difference between them is a small area.<span class="x" onmousemove="('comment',' By which area of two beth se'ah exceeds that of seventy and two-thirds cubits square (cf. infra n. 8) . According to the first Tanna the area may be as large as two beth se'ah while according to R. Akiba it must not exceed that of 70 2/3 cubits square.');"><sup>2</sup></span>
Teshuvot Maharam
A. If the major portion of the area of the garden is planted, it is considered a separate enclosure and a person is not permitted to carry objects on the Sabbath from the house to the garden or vice versa. But, if only a small part of the area of the garden is planted, the garden is considered part of the courtyard.
SOURCES: L. 144; cf. Mord. Erub. 485.