The rabbis debate the meaning of the verse in
Bava Batra 14b. מִצַּד is a rare combination, but it certainly means "beside" in
Jos. 3:16,
Jos. 12:9,
Ruth 2:14,
1 Sam. 20:25. I see no instances where it can unequivocally be asserted to mean "in," "inside," or "within." Had Moshe intended to say that it was placed "inside" the Ark, why wouldn't he have written ב or בקרב instead?
For example, using the same verb that is found in Deut. 31:26 (a conjugation of the verb
שׂוּם, meaning "to put" or "to place"), Isaiah writes (
Isa. 63:11),
...Where is He who put His Holy Spirit within him?
The prophet uses the prepositional phrase בְּקִרְבּוֹ (
bekirbo). The context makes it clear that God puts or places His Holy Spirit inside an individual.
Another example is
Deut. 10:2 where we find, again, the same verb, but this time, Moshe uses the prepositional prefix ב.
And I will write on the tables the words that were on the first tables which you broke, and you shall put them in the Ark.
Here, God commands Moshe to put the tables (which have the Ten Commandments written upon them)
in the Ark, which is translated from the Hebrew phrase בָּאָרוֹן (
ba'aron).
So, the tablets are placed בָּאָרוֹן, "in the Ark." Why not write the same for the Torah scroll if indeed it was located "in the Ark"? There's simply nothing which explicitly confirms that it was indeed located in the Ark. Again, the prepositional phrase מִצַּד is never used in a context meaning "inside" or "in."