Inciting and Incited Karmic Impulses in Madhyamaka

Sources of the Madhyamaka View of Karma

Let us survey the Madhyamaka view of karma, starting with Nagarjuna (Klu-grub, Skt. Nāgārjuna) in the late second century CE. It follows the Sarvastivada abhidharma assertion, also found in the Mahayana sutras, that the karmic impulses of the body and speech are revealing and nonrevealing forms. Nagarjuna’s formulation came about half a century after the Fourth Buddhist Council, which compiled the Vaibhashika interpretation of these abhidharma and sutra sources into The Great Extensive Commentarial Treatise on Special Topics of Knowledge (Chos mngon-pa bye-brag bshad-pa chen-mo, Skt. Abhidharma Mahāvibhāṣā). Since Nagarjuna refers to there being a more extensive presentation of the details of karma elsewhere, he was undoubtedly aware of The Great Extensive Commentarial Treatise while teaching at Nalanda Monastic University. He predates Vasubandhu, however, by about two centuries. 

Later Indian commentators on Nagarjuna’s texts, such as the early sixth-century masters Buddhapalita (Buddha-pā-li-ta, Sangs-rgyas bskyangs, Skt. Buddhapālita) and Bhavaviveka (Legs-ldan ‘byed, Skt. Bhāvaviveka), the seventh-century master Chandrakirti (Zla-ba grags-pa, Skt. Candrakīrti) and the eighth-century master Avalokitavrata (sPyan-ras-gzigs brtul-zhugs, Skt. Avalokitavrata), like Nagarjuna, were teachers at Nalanda Monastic University. By their times, not only Nagajuna’s texts but also the texts of Vasubandhu and his Indian commentators, such as Jinaputra Yashomitra (rGyal-sras Grags-pa bshes-gnyen, Skt. Jinaputra Yaśomitra) and Sthiramati (Blo-gros brtan-pa, Skt. Sthiramati), would also have been available and studied at Nalanda. These later Madhyamaka masters occasionally quote or paraphrase Vasubandhu’s texts.

The Prasangika division of Madhyamaka traces from Buddhapalita. Bhavaviveka refuted many of his contemporary, Buddhapalita’s, positions, though not his assertions about the divisions of karma. The Sautrantika-Svatantrika division of Madhyamaka traces from Bhavaviveka. Though the Yogachara-Svatantrika division of Madhyamaka, as elaborated by Shantarakshita (Zhi-ba ‘tsho, Skt. Śantarakṣita) and Kamalashila (Ka-ma-la shī-la, Skt. Kamalaśīla) in the eighth century, follows Asanga’s Chittamatra presentation of karma, it is clear from Bhavaviveka’s commentary on Nagarjuna’s works that he accepted Nagarjuna’s presentation. 

Chandrakirti was a defender of Buddhapalita against Bhavaviveka’s critique, and Avalokitavrata, in turn, defended Bhavaviveka against Chandrakirti’s critique.

There have been many Tibetan commentators on Nagarjuna’s texts. Here, we shall look at only a sample of them: those written by the Gelug founder Tsongkhapa (Tsong-kha-pa Blo-bzang grags-pa) (1357-1419), the Sakya master Gorampa (Go-ram-pa bSod-nams seng-ge) (1429-1489) and the Nyingma master Mipam (Mi-pham ‘Jam-dbyangs rnam-rgyal rgya-mtsho) (1846-1912). I have not been able to locate a Kagyu commentary. The commentaries I’ve found all explain Nagarjuna’s presentation without any indication that they disagree with each other about how to interpret it.  

Here, we shall survey these various Indian and Tibetan commentaries in chronological order.

The Division of Karma into Inciting and Incited Karmic Impulses

Nagarjuna writes in Root Verses on Madhyamaka, Called Discriminating Awareness (dBu-ma rtsa-ba’i tshig-le’ur byas-pa shes-rab ces bya-ba, Skt. Prajñā-nāma-mūlamadhyama-kārikā) (XVII.2) (Gretil. ed., Derge Tengyur vol. 96, 9B):

Inciting karmic impulses (sems-pa’i las, Skt. cetanākarma) and incited (karmic impulses) (bsam-pa’i las, Skt. cetayitvākarma) have been spoken of by the Supreme Sage (Buddha). The division of these two (kinds of) karmic impulses into many types has been proclaimed (by him).
(Skt.) cetanā cetayitvā ca karmoktam paramarṣiṇā, tasyānekavidho bhedaḥ karmaṇaḥ parikīrtitaḥ.
(Tib.) drang srong mchog gis las rnams ni sems pa dang ni bsams par gsungs, las de dag gi bye brag ni rnam par du mar yongs su bsgrags.

Nagarjuna states in his autocommentary, Commentary on “Root (Verses on) Madhyamaka,” (Called) Without Fear of Anything, (dBu-ma rtsa-ba’i ‘grel-pa ga-las ‘jigs-med, Skt. Mūlamadhyamakavṛtti-akutobhayā) (Derge Tengyur vol. 96, 64A), that his sources about karma are Buddha’s proclamations in an abhidharma text:

Since this division of those two (types of) karmic impulses has been proclaimed extensively (by him) in the abhidharma (text), here, with the aim of leaving out the elaborate (detail), it will not be discussed. 

(Tib.) las de dag gi bye brag rgyas par ni chos mngon pa las gsungs pas 'phros pa bsal ba'i phyir 'dir ma brjod de/ 

The extensive explanation of karma in an abhidharma text is most likely a reference to The Great Extensive Commentarial Treatise on Special Topics of Knowledge. 

Chandrakirti adds in Clarified Words: Commentary on “Root (Verses on) Madhyamaka” (dBu-ma rtsa-ba’i ‘grel-pa tshig-gsal-ba, Skt. Prasannapadā-madhyamaka-vṛtti), (Gretil. ed. 133, Derge Tengyur vol. 102, 102A): 

Inciting karmic impulses and incited (karmic impulses) have been spoken of by the Supreme Sage (Buddha) in a sutra.
(Skt.) tena paramarṣiṇā cetanā karma, cetayitvā ca karmetyuktaṃ sūtre
(Tib.) /drang srong mchog des mdo las/ sems pa'i las dang bsams pa'i las so zhes gsungs so/

The reference is to an unnamed sutra that is not found in Tibetan translation in the Kangur collection. From among the sutras translated and included in the Kangyur, however, incited karmic impulses are mentioned in The Sutra on Repaying the Kindness of the Buddha, the Great Skillful One in Methods (Thabs-mkhas-pa chen-po sangs-rgyas drin-lan bsab-pa’i mdo) (Derge Kangyur vol. 76, 174A-B, 175A):

Being like that, the revealing form of the ethical self-discipline during that first phase of mind (when requesting and obtaining a pratmoksha vowed restraint) is brought about as (something caused by) a previous urging (bsam-pa). It is called a “pathway of an incited karmic impulse” by means of it (being in a pathway that) contains (something caused by) a previous urging.
(Tib.) /de lta bas na sems kyi skad cig ma dang po las tshul khrims kyi rnam par rig byed kyi gzugs bsam pa yongs su rdzogs te/ bsam pa dang ldan pas bsam pa’i las kyi lam zhes bya’o/

Nagarjuna’s Definition of Inciting and Incited Karmic Impulses

Nagarjuna continues in his Root Verses (XVII.3) (Gretil. ed., Derge 9B):

Out of these, that karmic impulse that has been spoken of as inciting has been recorded as (being) a (karmic impulse) of the mind, and that which has been spoken of as incited is a (karmic impulse) of the body or of the speech. 
(Skt.) tatra yac cetanety uktaṃ karma tan mānasaṃ smṛtam, cetayitvā ca yat tūktaṃ tat tu kāyikavācikam.
(Tib.) de la las gang sems pa zhes gsungs pa de ni yid kyir ‘dod, bsams pa zhes ni gang gsungs pa de ni lus dang ngag gir yin/

Note that Nagarjuna’s usage of the Sanskrit term “smṛtam” in this and in the following two verses, meaning “recorded,” indicates that his statements are based on previously recorded written sources (smṛti), namely the sutras and the abhidharma texts. The Tibetan translation, “‘dod,” merely means “accepted” or “asserted.”

Nagarjuna does not comment on this line in his Autocommentary.

Buddhapalita’s Commentary

Buddhapalita writes in his Buddhapalita Commentary on “Root (Verses on) Madhyamaka” (dBu-ma rtsa-ba’i ‘grel-pa buddha-pā-li-ta, Skt. Buddhapalita Mūlamadhyama-vṛtti) (Derge Tengyur vol. 96, 231B, 232A):

An inciting karmic impulse is (a karmic force) that has taken on (the essential nature of) a karmic tendency, and an incited karmic impulse is one that it initiates at a later time… Concerning these, the karmic impulse that has been spoken of as “inciting” has been recorded as (being) a (karmic impulse) of the mind, and that (which is incited) is a (karmic impulse) of the body or of the speech. That which has been spoken of as “incited” is that which is enacted by the body or speech, having thought with the premeditating intellect, “I shall do this.” That which has been enacted without having thought (beforehand to do it) is not (an incited karmic impulse). 
(Tib.) / sems pa sa bon du gyur pa dang / bsam pa dus phyi ma la rtsom par byed pa gang yin pa'o/ …  /de la las gang sems pa zhes/ /gsungs pa de ni yid kyir 'dod/ bsam pa zhes ni gang gsungs pa/ /de ni lus dang ngag gi yin/ /de la las gang sems pa zhes gsungs pa de ni yid kyi yin par 'dod do/ /las gang bsams pa zhes gsungs pa blos 'di bya'o snyam du gsungs nas lus sam ngag gi byed pa de ni lus dang ngag gi yin te gang ma bsams par byas pa ni ma yin no/ 

An inciting karmic impulse is the mental factor of an urge, while incited karmic impulses are revealing and nonrevealing forms. Constructive karmic impulses are a positive karmic force (positive karmic potential) (bsod-nams, Skt. puṇya; “merit”), while destructive karmic impulses are a negative karmic force (negative karmic potential) (sdig-pa, Skt. pāpa). When a constructive or destructive karmic impulse ceases, the karmic force takes on the essential nature of a karmic tendency (sa-bon-gyi ngo-bor gyur-pa). Like a karmic tendency (sa-bon, Skt. bīja), the karmic force becomes a noncongruent affecting variable (ldan-min ‘du-byed, Skt. viprayuktasaṃskāra), a nonstatic phenomenon that is neither a form of physical phenomenon nor a way of being aware of something and that is an imputation phenomenon on the basis of the mental consciousness. Unlike a karmic tendency, which is always an unspecified phenomenon, the karmic force that takes on the essential nature of a karmic tendency remains either constructive or destructive.

In stating “An inciting karmic impulse is (a karmic force) that has taken on (the essential nature of) a karmic tendency, and an incited karmic impulse is one that it initiates at a later time,” Buddhapalita indicates that there may be a time gap between an inciting karmic impulse and the incited karmic impulse that it brings on. If there is such a time gap, then the inciting karmic impulse transforms from having the essential nature of a mental urge to having the essential nature of a karmic tendency – namely, the essential nature of a noncongruent affecting variable – that when activated, functions as the inciting karmic impulse that “initiates at a later time” an incited karmic impulse. This means that the activated inciting karmic impulse (a mental urge) directly brings on the non-karmic mental urge that drives the sensory consciousness and its other accompanying mental factors in engaging the body or speech to enact a karmic action of the body or speech by means of an incited karmic impulse.

Further, Buddhapalita makes it clear that not all karmic impulses of the body and of the speech are incited karmic impulses. He implicitly implies that, likewise, not all karmic impulses of the mind are inciting karmic impulses – for instance, ones that do not bring on karmic impulses of the body or of the speech. 

Bhavaviveka’s Commentary

Bhavaviveka adds further detail in Lamp for Discriminating Awareness: A Commentary on “Root (Verses) for Madhyamaka” (dBu-ma rtsa-ba’i ‘grel-pa shes-rab sgron-ma, Skt. Prajñapradīpa Mūlamadhyama-vṛtti) (Derge Tengur, vol. 97, 171B):

“That karmic impulse that has been spoken of as ‘inciting’ has been recorded as (being) a (karmic impulse) of the mind.” This is because “of the mind” means that it has been produced from the mind and concludes solely through the gateway of the mind. (Karmic impulses) of the body and of the speech are not spoken of as mental urges because, although they are caused to arise (motivated) by a mental urge, they complete through the gateway of the body and speech. 
“Incited” is “that which is enacted subsequent to the premeditating intellect premeditating (it),” (blos bsams-nas byed-pa, Skt. saṃcetanaḥ saṃcintya kṛtaṃ). Thus, what are spoken of as “incited karmic impulses” are (karmic impulses) of the body and of the speech because they have been produced from the body or speech and conclude through the gateway of those two themselves. Because it is like that, two types of karmic impulses have been indicated.
(Tib.) /las gang sems pa zhes gsungs pa de ni yid kyir 'dod de/ yid kyi zhes bya ba ni yid las byung ba ste/ yid kyi sgo kho na nas de mthar thug bar 'gyur ba'i phyir ro/ /lus kyi dang ngag gi dag ni sems pa zhes mi brjod de/ de dag sems pas kun nas bslang ba yin yang lus dang / ngag gi sgo nas yongs su rdzogs pa'i phyir ro/ /bsam pa zhes ni gang gsungs pa/ /de ni lus dang ngag gi yin/ /bsam pa zhes bya ba ni blos bsams nas byed pa gang yin pa ste/ de ltar las gang bsam pa zhes bya ba gsungs pa ni lus dang ngag gi yin te/ lus dang ngag las byung ba'i phyir dang / de dag gi sgo nyid nas mthar thug par 'gyur ba'i phyir ro/ 

Chandrakirti’s Commentary

Chandrakirti adds in Clarified Words (Gretil. 133, Derge 102A):

Being something in the mind (is the meaning) “of the mind,” because it goes to its conclusion through the gateway of the mind, and because it is not dependent on an engagement with the body or speech. Being only congruent with mental consciousness, an inciting (karmic impulse) is called a “karmic impulse of the mind.” The word “out of these” specifies that. 
As for the second (type of) karmic impulse, called “incited karmic impulses,” they are to be known, on the other hand, as being of the body and of the speech. That which is enacted, premeditated by the mind, “I shall engage like this and like this with (my) body and speech,” is spoken of as an incited karmic impulse. Again, that is twofold: (a karmic impulse) of the body and of the speech. That is because they are in the body and speech and because they go to their conclusion through the gateway of these two. Thus, the threefold (division of karmic impulses) is (karmic impulses) of the body, of the speech, and of the mind. 
(Skt.) manasi bhavaṃ mānasam, manodvāreṇaiva niṣṭhāgamanāt kāyavākpravṛttinirapekṣatvācca manovijñānasaṃprayuktaiva cetanā mānasaṃ karmetyucyate, tatraśabdo nirdhāraṇe, yattu dvitīyaṃ cetayitvā ca karmetyuktam, tatpunaḥ kāyikaṃ vācikaṃ ca veditavyam, evaṃ ca evaṃ ca kāyavāgbhyāṃ pravartiṣye ityevaṃ cetasā saṃcintya yat kriyate, taccetayitvā karmetyucyate. tatpunardvividham, kāyikaṃ vācikaṃ ca, kāyavācorbhavatvāt taddvāreṇa ca niṣṭhāgamanāt, evaṃ ca trividham kāyikaṃ vācikaṃ mānasaṃ ca.
(Tib.) /yid la yod pa ni yid kyi ste/ yid kyi sgo nas de mthar thug par 'gro ba'i phyir dang / lus dang ngag 'jug pa la ltos pa med pa'i phyir yid kyi rnam par shes pa dang mtshungs par ldan pa'i sems pa kho na la yid kyi las zhes brjod do/ / de la zhes bya ba'i sgra ni dmigs kyis bkar ba'o/ /las gnyis pa bsams pa zhes gang gsungs pa de ni lus dang ngag gi yin par rig par bya ste/ lus dang ngag dag gis de lta de ltar 'jug par bya'o zhes de ltar sems kyis bsams nas gang zhig byed pa de ni bsams pa'i las zhes bya'o/ /yang de ni rnam pa gnyis te/ lus dang ngag la yod pa'i phyir dang / de dag gi sgo nas mthar thug par 'gro ba'i phyir na lus kyi dang ngag gi'o/ /de ltar na lus kyi dang ngag gi dang yid kyi ste/ rnam pa gsum du 'gyur ro/

Avalokitavrata’s Commentary

Avalokitavrata explains in Extensive Subcommentary to (Bhavaviveka’s) “Lamp for Discriminating Awareness,” (Shes-rab sgron-ma rgya-cher ‘grel-pa, Skt. Prajñāpradīpam-ṭīkā) (Derge Tengyur, vol. 101, 21A-B):

As for (Nagarjuna’s) statement (quoted by Bhavaviveka), “That karmic impulse that has been spoken of as ‘inciting’ has been recorded as (being) a (karmic impulse) of the mind” – it is recorded as a karmic impulse of the mind since the affecting mental urge (that is the karmic impulse of the mind) does not cause the mind to move like a magnet causing iron filings (to move). Furthermore, gathering together constructive, destructive and unspecified mental urges, there are three (types of) karmic impulses (for actions of) of the mind. 
(Tib.) /las gang sems pa zhes gsungs pa de ni yid kyir 'dod de zhes bya ba la/ 'du byed sems pa ni kha ba len gyis lcags g.yo bar byed pa bzhin du/ /yid g.yo bar byed pa ma yin pas yid kyi las su 'dod de/ de yang dge ba dang / mi dge ba dang lung du ma bstan pa'i sems pas bsdus pa yid kyi las gsum po dag go/

Vasubandhu, in his Sautrantika text, A Discussion for the Establishment of Karma (Las-grub-pa’i rab-tu byed-pa, Skt. Karmasiddhiprakaraṇa) (Derge Tengyur vol. 136, 145A), differentiates “functional” impulses (byed-pa’i las, Skt. kāritrakarma) from “exertional” impulses (rtsol-ba-can-gyi las, Skt. vyavasāyakarma). Both impulses are the mental factor of an urge. “Functional” impulses occur with sensory or mental cognition of an object – seeing, hearing and so on. “Exertional” impulses occur in the context of karmic actions of the body, speech and mind. Only exertional impulses are karmic impulses.  

In the case of cognition of an object, the “functional” mental urge, like a magnet drawing iron filings along with it as it moves, draws one of the five types of sensory consciousness or mental consciousness, together with its accompanying mental factors, toward an object to be cognized. The “exertional” mental urge that is an inciting karmic impulse, on the other hand, accompanies only conceptual mental consciousness engaged in considering and deciding to commit an action of the body or speech. Although the thinking of the karmic action of the mind is directed at the body and speech, the mental urge that is congruent with the mental consciousness does not move the mental consciousness and its accompanying mental factors, like a magnet moving iron filings, to the body or speech in order to think about committing an action with one of the two. 

Consider, for example, the “exertional” mental urge that is an inciting karmic impulse in the action of the mind of covetous thinking – for example, thinking about and deciding to commit an action of the body to steal someone’s watch. The mental urge accompanies the mental consciousness during the mental action of thinking about doing something with the body, but it does not draw the mental consciousness toward the body in order to cognize and think about it. 

Avalokitavrata continues:

As for (Bhavaviveka’s) statement, “This is because “of the mind” means that it has been produced from the mind and concludes solely through the gateway of the mind,” the term “of the mind” needs specifically to be explained. It is “of the mind” since the affecting mental urge is (the type of) phenomenon (that is) a mental factor – (one of the ten) great factors grounded in all mental states. (Thus), it is produced with and possessed by the mind in the manner of (arising together with a consciousness that is) the cognitive stimulator that is a mind (sensor) – (the two) being inseparable through congruence of placement, focal object, aspect, substantial entity and time. (It is also “of the mind”) because it is solely through the gateway of the cognitive stimulator that is a mind (sensor) that an affecting mental urge – generating (a mind) in the nature of covetous thinking, thinking with malice, or antagonistic, distorted thinking, or in the nature of what is turned away (from them) or in the nature of unspecified (thinking) – concludes and completes. 
(Tib /yid kyi zhes bya ba ni yid las 'byung ba ste/ yid kyi sgo kho na nas de mthar thug par 'gyur ba'i phyir ro zhes bya ba ni/ yid kyi zhes bya ba'i sgra bye brag tu bshad pa ste/ 'du byed sems pa ni sems las byung ba'i chos sa mang po pa yin pas gnas dang / dmigs pa dang / rnam pa dang / rdzas dang / dus mtshungs pa'i sgo nas yid kyi skye mched gnyis dang / tha mi dad pa'i tshul du yid la byung zhing yod pas yid kyi zhes bya ba ste/ yid kyi skye mched kyi sgo kho na nas 'du byed sems pa brnab sems dang / gnod sems dang / log par lta ba'i rang bzhin nam/ de dag las ldog pa'i rang bzhin nam/ lung du ma bstan pa'i rang bzhin du skye ba de mthar thug cing yongs su rdzogs par 'gyur ba'i phyir ro/

In general, the cognitive stimulator that is a mind sensor (yid-kyi skye-mched) includes any of the six types of consciousness that serves as the immediately preceding condition (de-ma-thag rkyen) for the arising of the mental consciousness with which a karmic action of the mind is committed. During the karmic action of the mind, the cognitive stimulator that is a mind sensor refers only to the mental consciousness driving the mind during the action. For example, in the moment immediately before an inciting karmic impulse arises driving the karmic action of the mind that thinks about and decides to steal a watch, a “functional” mental urge may have moved the eye consciousness and its accompanying mental factors to the watch when seeing it. During the karmic action of the mind, an “exertional mental” urge then accompanies the mental consciousness, driving it during the course of the karmic action of the mind.

Both the “functional” mental urge and the “exertional” mental urge are congruent with the consciousness and mental factors that they accompany. They all share five congruent features (mtshung-ldan lnga, Skt. pañcasamprayuktā) in common. Being a proponent of Sautrantika-Svatantrika Madhyamaka, Avalokitavrata follows not only the Sautrantika assertion of “functional” and “exertional” impulses, but also the Vaibhashika presentation of the mental factors and the five features of congruence that Sautrantika also accepts.

The ten great factors grounded in all mental states (sa-mang-po, Skt. mahābhūmika) include not only mental urges, but also intention (‘dun-pa, Skt. chandas), distinguishing (‘du-shes, Skt. saṃjñā), feeling a level of happiness (tshor-ba, Skt. vedanā), and so on. 

As for the five congruent features: 

  • Placement (gnas, Skt. sthāna) refers to the same cognitive sensor as what they rely on to arise.
  • Focal object (dmigs-pa, Skt. ālambana) refers to the same cognitive object they focus on.
  • Aspect (rnam-pa, Skt. ākāra), according to Vaibhashika, refers to the same aspect they directly take on; according to Sautrantika, they refer to the same mental representation of the object focused on, somewhat like a mental hologram.
  • Time (dus, Skt. kāla) refers to arising simultaneously
  • Substantial entity (rdzas, Skt. dravya) refers to each being a member of its own homogeneous class of all items of the same type.

An inciting karmic impulse is an impulse of the mind since it arises simultaneously with the mental consciousness and, when the action of the mind reaches its conclusion – for instance, deciding to steal the watch – it ceases simultaneously with the mental consciousness.

Avalokitavrata goes on:

Suppose you ask, why aren’t karmic impulses of the body and of the speech (also) spoken of as (being) mental urges? The two (karmic impulses) of body and speech are not spoken of as (being) mental urges because it is stated that although they are caused to arise (motivated) by a mental urge, they complete through the gateway of the body or speech. (Thus), although the three karmic impulses of the body and the four karmic impulses of speech – these seven phenomena – are caused to arise by a mental urge, they are not mental urges. They are not spoken of as mental urges because, being in the nature of speech and movement and (thus) included in the aggregate of forms of physical phenomena, they complete through the gateway of the body or speech as being in the essential nature (of) an abstention (from committing a destructive action), a non-abstention (from committing a destructive action) or what is turned from both.
(Tib) /'o na lus dang ngag gi las dag sems pa zhes bya ba ci'i phyir mi brjod ce na/ de'i phyir lus kyi dang ngag gi dag ni sems pa zhes mi brjod de/ de dag sems pas kun nas bslang ba yin yang lus dang ngag gi sgo nas yongs su rdzogs pa'i phyir ro zhes bya ba smras te/ lus kyi las gsum dang / ngag gi las bzhi ste/ chos bdun po de dag ni sems pas kun nas bslang ba yin yang sems las byung ba'i chos ma yin te/ ngag dang bskyod pa'i rang bzhin gzugs kyi phung por gtogs pa yin pas lus dang ngag gi sgo nas spong ba dang / spong ba ma yin pa dang / de gnyis las bzlog pa'i ngo bo nyid du yongs su rdzogs par 'gyur ba'i phyir sems pa zhes bya bar mi brjod do/
Although an “exertional” karmic impulse that is a mental urge causes an incited karmic impulse of the body or speech to arise, the incited karmic impulse is not a mental urge, but rather is a form of physical phenomenon.

Avalokitavrata says further:

As for “what are spoken of as ‘incited karmic impulses’ are (karmic impulses) of the body and of the speech” – in order to indicate the defining characteristic of “incited” (literally, what has been thought about), it was stated that “incited” (means) “that which is enacted, having been thought about by the premeditating intellect.” Whatever karmic impulses of the body or of the speech that have been enacted, having been caused to arise from having been thought about by the premeditating intellect – referring to (at the time of) the affecting inciting mental urge – they are called “incited karmic impulses.” This is because they are not produced without being affected by having investigated and analyzed beforehand. Because it indicates their actual nature (de-nyid), whatever karmic impulses like this have been spoken of as “incited” are stated to be “of the body or of the speech.”
(Tib.) /bsam pa zhes ni gang gsungs pa/ /de ni lus dang ngag gi yin/ /zhes bya ba la/ bsam pa zhes bya ba'i mtshan nyid bstan pa'i phyir/ bsam pa zhes bya ba ni blos bsams nas byed pa gang yin pa ste zhes bya ba smras te/ 'du byed sems pa zhes bya ba'i blos bsams nas des kun nas bslang ste/ lus dang ngag gi las byed pa gang yin pa de dag ni bsam pa'i las zhes bya ste/ ma brtags ma dpyad par las mngon par 'du mi byed do zhes 'byung ba'i phyir ro/ /de nyid bstan pa'i phyir/ de ltar las gang bsam pa zhes gsungs pa de ni lus dang ngag gi yin te zhes bya ba smras so/

A karmic action of the body or speech implemented by an incited karmic impulse (a form of physical phenomenon) is one that is preceded by a karmic action of the mind, in which the mental consciousness is accompanied by an inciting karmic impulse (a mental urge) that is congruent with it. Also congruent with that mental consciousness and inciting urge are the mental factors of investigation (rtog-pa, Skt. vitarka) and scrutiny (dpyod-pa, Skt. vicāra). Covetously thinking about and deciding to commit a karmic action of the body, such as stealing a watch, requires rough investigation and subtle scrutiny of the pros and cons, time, method and so on for carrying out the theft. This investigation and scrutiny is referred to as being carried out with the premeditating intellect (blo, Skt. saṃcetana). 

Avalokitavrata concludes:

As for “because they have been produced from the body or speech and conclude through the gateway of those two themselves,” it is specifically explaining the terms “of the body and of the speech.” They are “karmic impulses of the body and karmic impulses of the speech” because (1) the three karmic impulses of the body and the four karmic impulses of speech, having been caused to arise (motivated by) a mental urge that is constructive, destructive, or unspecified, are produced from the body and speech, which are included in the aggregate of forms of physical phenomena, and because (2) they conclude through the gateway of the body or speech itself as having the essential nature of being constructive, destructive or unspecified.
(Tib.) /lus dang ngag las byung ba'i phyir dang / de dag gi sgo nyid nas mthar thug par 'gyur ba'i phyir ro zhes bya ba ni/ lus kyi dang ngag gi zhes bya ba'i sgra bye brag tu bshad pa ste/ lus kyi las gsum dang ngag gi las bzhi po dge ba dang mi dge ba dang lung du mi bstan pa'i sems pas kun nas bslang ba dag ni gzugs kyi phung por gtogs pa'i lus dang ngag las byung ba'i phyir dang lus dang ngag gi sgo nyid nas dge ba'am mi dge ba'am lung du ma bstan pa'i ngo bo nyid du mthar thug par 'gyur ba'i phyir lus kyi las dang ngag gi las zhes bya'o//

The incited karmic impulses of the body being movements of the body and the incited karmic impulses of speech being utterances of words, these karmic impulses remain as impulses of the body or speech from the initiation of the karmic action until the action’s end 

Tsongkhapa’s Commentary

Tsongkhapa, in An Ocean of Reasonings: An Explanation of Verses on Root Madhyamaka, Called Discriminating Awareness,” (dBu-ma rtsa-ba’i tshig-le’ur byas-pa shes-rab-ces-bya-ba’i bshad rigs-pa’i rgya-mtsho), (Drepung Gomang Monastery ed., 262), paraphrases Chandrakirti’s commentary: 

As for the two (types of) karmic impulse spoken of, that which, among them, is called an “inciting karmic impulse” and which has been spoken of before is exclusively a mental urge that is congruent with a mental consciousness. It is recorded as being of the mind because of its being in the mind and because it concludes through the gateway of the mind and is not dependent on an engagement with the body or speech. What is called an “incited karmic impulse” is to be known as (a karmic impulse of the) body or of speech because it is enacted after having been thought by the premeditating intellect, “I shall engage myself through the gateway of the body or speech like this.”
(Tib.) las gnyis gsungs pa de la ste de’i nang nas sems pa’i las zhes sngar gang gsungs pa de ni yid kyi rnam shes dang mtshungs par ldan pa’i sems pa kho na yin te/ yid kyir ‘dod pa ste yid la yod pa’i phyir dang yid kyi sgo nas de mthar thug par ‘gro zhing lus dang ngag ‘jug pa la ltos pa med pa’i phyir ro/ bsams pa’i las zhes gang gsungs pa de ni lus dang ngag yin par rig par bya ste lus dang ngag gi sgo nas de ltar ‘jug par bya’o snyam du sems kyi bsams nas byed pa’i phyir ro/  

Gorampa’s Commentary

Gorampa explains in Rays of Light of the Correct View: An Explanatory Commentary on Root Verses on Madhyamaka, (Called) Discriminating Awareness,” (dBu ma rtsa ba’i shes rab kyi rnam par bshad pa yang dag lta ba’i ‘od zer) (gSungs ‘bum bSod nams seng ge, Sakya College ed., vol.4, 650): 

The karmic impulse that is called “inciting” is recorded as being of the mind because of either its being (a mental urge) possessed in the mind or its being a mental urge that is congruent with mental (consciousness). That which is spoken of as “incited” is recorded as being (a karmic impulse of the) body or of speech because of either its being in the body or speech or its (something brought on by) a mental urge that is coursing at the same time as the body or speech.  
(Tib.) las gang sems pa zhes gsungs pa de ni yid kyir ‘dod de/ yid la yod pa’am yid kyi mtshungs ldan gyi sems pa yin pa’i phyir ro/ bsam pa zhes ni gang gsungs pa de ni lus dang ngag gi yin par ‘dod de/ lus dang ngag la yod pa’am/ lus ngag dang dus mnyam su rgyu ba’i sems pa yin pa’i phyir ro/
Mipam’s Commentary

Mipam, in Filigree for the King of the Naga’s Intention, Clarifying Completely the Abiding Nature, A Word-for Word Commentary on “Root (Verses on) Madhyamaka,” (dBu-ma rtsa-ba’i mchan-‘grel gnas-lugs rab-gsal klu-dbang dgongs-rgyan) (Sonam Topgay Kazi, Gangtok ed., 190), elaborating on Buddhapalita’s point, “That which has been enacted without having thought (beforehand to do it) is not (an incited karmic impulse), explains:

Concerning that, the karmic impulse that is spoken of “inciting” is recorded as being a karmic impulse of the mind and in the division of mind. As for what is spoken of as a “karmic impulse enacted having been incited,” it is called a karmic impulse of the body or of speech, because the name of its cause – not being possible without having been incited – is labeled on its result. Like this, there are three (types of) karmic impulses of the three gateways (mind, body and speech).
(Tib.) de la las gang zhig sems pa zhes bya ba gsungs pa de ni yid kyi sde yid kyi las yin par ‘dod la, bsams par byas pa’i las zhes ni gang gsungs pa de ni ma bsam par bya mi nus pa’i rgyu ming ‘bras bur btags pas lus dang ngag gi las zhes bya ba yin te de lta na sgo gsum gyi las gsum mo/
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