Spilling water onto fertile soil is forbidden because of "Zore'a" - planting, since the water could help things grow.
Therefore one should refrain from eating in the garden, since it's almost impossible that something won't be spilt onto the floor.
This is besides the problem that one cannot always carry into the garden unless there's a proper Eruv.
Source: Kitzur Shulchan Aruch 80:28
Shabbat Shalom,
- Danny
Thursday, 18 Marcheshvan 5770
Thursday, November 5, 2009
Halocho #443 - Shabbat meals in the garden
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