Abu Dawud

Benefits and Issues:
➊
The statement of the Companion that "this is Sunnah" is considered to be in the meaning of a marfu' hadith (attributed directly to the Prophet sallallahu alayhi wa sallam).
It has no connection to the Companion's own analogy (qiyas) or independent reasoning (ijtihad).
➋
After the first takbir, the recitation of al-Fatihah should be done.
➌
This hadith is also evidence for reciting the funeral prayer (janazah) in an audible voice.

1989. Commentary: It is established that recitation of Surah Al-Fatihah is necessary in the funeral prayer (Salat al-Janazah) as well. Sunnah here refers to the method prescribed by the Prophet sallallahu alayhi wa sallam. Here, "Sunnah" is not in contrast to obligation (wujub), as is clearly evident from the word "haqq" (right). The generality of «لا صلاۃ لمن لم یقرأ بفاتحۃ الکتاب» (Sahih al-Bukhari, al-Adhan, Hadith: 756, and Sahih Muslim, al-Salat, Hadith: 394) also makes the recitation of Al-Fatihah obligatory. The majority of scholars hold this view. The Hanafis, without any valid reason, oppose the recitation. In response to this hadith, they say that Ibn Abbas radi Allahu anhuma did not recite Surah Al-Fatihah and another surah with the intention of recitation (qira’ah), but rather with the intention of supplication (du‘a). However, there should be some evidence for this "would have" (i.e., their claim). After all, what prevents the recitation of Al-Fatihah? Is the fact that the funeral prayer is a supplication contrary to recitation? In the regular prayers, Al-Fatihah is recited as well as supplications—what kind of combining of two opposites is this?

Reciting Surah Al-Fatihah in the Funeral Prayer

Reciting Surah Al-Fatihah in the funeral prayer (salat al-janazah) is Sunnah. [صحيح بخاري ج1 ص178 ح1335]

That is, it is the Sunnah of the Noble Prophet sallallahu alayhi wa sallam, and in this hadith, there is also mention of reciting a surah after Surah Al-Fatihah. [سنن النسائي ج1 ص281 ح1989، وسنده صحيح، المنتقي لابن الجارود: 534، 536]

Reciting the funeral prayer silently (sirran) is also permissible. [منتقي ابن الجارود: 504]
And reciting it aloud (jahran) is also permissible. [سنن النسائي: 1989]

In a narration attributed to Sayyiduna Abdullah ibn Mas'ud radi Allahu anhu, it is mentioned: "No recitation has been prescribed for us in the funeral prayer, nor any specific utterance." Sahih Ahmad? Referenced in [مجمع الزوائد ج3 ص32]

This narration is not found in Musnad Ahmad; therefore, due to being without a chain of transmission, it is rejected. A similar narration is reported from Abdullah ibn Ahmad ibn Hanbal. [المعجم الكبير للطبراني 373/9 ح9604]

Its chain is weak due to the 'an' of Sharik al-Qadi (a mudallis).

In a narration in Al-Mu'jam Al-Kabir [373/9 ح9606], and Al-Thiqat of Ibn Hibban [259/9], besides Sharik the mudallis, Jabir (al-Ju'fi) is extremely weak.

Also see: [العلل للدارقطني 262/5 س867]

In summary, this narration is unestablished and rejected.

Zuhur Ahmad, on the last page of "Chehl Hadith," has also quoted weak and unestablished reports in this regard, which have no standing in the field of scholarship.

For details, see [هدية المسلمين ص89۔ 90 ح40]

... See the original article ...

Fatawa Ilmiyyah (Tawdih al-Ahkam) Vol. 2, p. 77

Explanation:
1:
Those people say that the narrations from which reciting Surah Al-Fatihah after the first takbir is established should be interpreted as meaning that it was recited with the intention of supplication, not with the intention of recitation. However, this is merely an interpretation for which there is no evidence.

The actions of the innovators are also strange and peculiar: they will not recite Surah Al-Fatihah in the funeral prayer (salat al-janazah) as established from the Prophet (sallallahu alayhi wa sallam) and the noble Companions (radi Allahu anhum), but in the customs of “Qul,” “third day,” “seventh day,” etc., they will repeatedly recite Al-Fatihah—and even then, it is not known which Fatihah they recite, for without the water pipe (huqqa), it is not accepted among them.

So, how astonishing are these superstitions!

Commentary:
Note:
(This hadith is authentic due to its corroboration by the following narration; otherwise, its narrator "Ibrahim ibn Uthman" is weak.)

Benefits and Issues:
The mentioned narration is weak in its chain of transmission.
However, in meaning and content, it is correct.
Because regarding the recitation of Surah al-Fatihah in the funeral prayer (salat al-janazah), it is narrated authentically in Sahih al-Bukhari from Talhah bin Abdullah bin Awf, who states that he performed a funeral prayer with Ibn Abbas (radi Allahu anhu), and he recited Surah al-Fatihah and said, "This is Sunnah." (Sahih al-Bukhari, al-Jana'iz, Chapter: Recitation of al-Fatihah over the deceased, Hadith: 1335)
And when a Companion says, "This is Sunnah," it is considered as having the meaning of a marfu' (attributed to the Prophet) hadith.
It has no connection to the Companion's own analogy or independent reasoning (ijtihad).
Therefore, from the statement of Ibn Abbas (radi Allahu anhu), "This is Sunnah," it is understood that the Messenger of Allah (sallallahu alayhi wa sallam) also used to recite Surah al-Fatihah in the funeral prayer.
As is also found in the narration of Sunan al-Nasa'i.
See: (Sunan al-Nasa'i, al-Jana'iz, Chapter: Supplication, Hadith: 1991)
Therefore, despite the mentioned narration being weak in its chain, in light of other ahadith, it is practicable and a valid proof, and the hadith that follows also establishes the same issue.

Lexical Explanation:
«لِتَعْلَمُو اَنَّها سُنَّةٌ» So that you may know that this method is derived from the Prophet sallallahu alayhi wa sallam. Here, "Sunnah" does not refer to the Sunnah as opposed to the obligatory (fard). This is a modern term used by the jurists (fuqaha), therefore, it does not negate its obligatory nature.

Benefit: Ibn Abbas radi Allahu anhuma recited Surah Al-Fatihah aloud and also explained the reason: that he did so to show you that this is Sunnah. Thus, reciting Surah Al-Fatihah aloud in the funeral prayer (salat al-janazah) is also permissible.

Narrator of the Hadith:
[ طلحہ بن عبداللہ بن عوف رحمہ اللہ ] This refers to Talhah bin Abdullah bin Awf rahimahullah. He was a Zuhri, a Qurashi, and a resident of Madinah. He was the nephew of the well-known and famous Companion, Abdur Rahman bin Awf radi Allahu anhu. He was famous by the title "Talhah Nadi." He was trustworthy (thiqah) and a jurist (faqih) of high standing. He was counted among the middle generation of the Tabi‘in. He passed away in the year 97 AH at the age of 72.

Hadith Commentary:
Reciting Surah al-Fatihah in the funeral prayer is just as obligatory as in other prayers, because the hadith:
«لاَ صَلاَةَ لِمَنْ لَمْ يَقْرَأْ بِفَاتِحَةِ الكِتَابِ» includes every prayer.
Its details, in the words of Hazrat Maulana Ubaidullah Sahib Shaykh al-Hadith rahimahullah, are as follows:
The truth and correct position is that reciting al-Fatihah in the funeral prayer is obligatory, as held by al-Shafi’i, Ahmad, Ishaq, and others; because they are unanimous that it is a prayer, and the hadith “There is no prayer except with the Opening of the Book (al-Fatihah)” is established, so it falls under the generality, and to exclude it from this generality requires evidence. Also, because it is a prayer in which standing is obligatory, so recitation is obligatory in it like other prayers. And because the command to recite it has come explicitly, as Ibn Majah has narrated with a slightly weak chain from Umm Sharik who said:
The Messenger of Allah (sallallahu alayhi wa sallam) commanded us to recite the Opening of the Book (al-Fatihah) over the funeral. Al-Tabarani has also narrated in al-Kabir from Asma bint Yazid who said:
The Messenger of Allah (sallallahu alayhi wa sallam) said:
“When you pray over the funeral, recite the Opening of the Book.” Al-Haythami said:
In its chain is Mu’alla ibn Humran, and I did not find anyone who mentioned him, but the rest of its narrators are trustworthy, though there is some discussion about some of them.
Furthermore, Hasan al-Sharnbalali, one of the later Hanafis, authored a treatise on this issue called “al-Nazm al-Mustatab li-Hukm al-Qira’ah fi Salat al-Janazah bi-Umm al-Kitab,” in which he established that recitation is preferable to leaving it, and there is no evidence for its dislike. This is also what Shaykh Abdul Hayy al-Laknawi chose in his works such as ‘Umdat al-Ri’ayah, al-Ta’liq al-Mumajjad, and Imam al-Kalam.
Then, evidence for reciting al-Fatihah aloud in the funeral prayer is taken from the hadith of Ibn Abbas, as it clearly shows that he recited it aloud so that those praying behind him heard it. Even clearer is what we mentioned from the narration of al-Nasa’i with the wording:
“I prayed behind Ibn Abbas over a funeral, and he recited the Opening of the Book and a surah aloud until he made us hear it. When he finished, I took his hand and asked him about it. He said:
‘It is Sunnah and truth.’” In another narration from him as well:
“I prayed behind Ibn Abbas over a funeral and heard him recite the Opening of the Book, etc.”
The hadith of ‘Awf ibn Malik, which will come, also indicates reciting the supplication aloud, as it appears that he memorized the mentioned supplication because the Prophet (sallallahu alayhi wa sallam) recited it aloud in the funeral prayer. Even clearer is the hadith of Wathilah in the second section.
The scholars have differed on this. Some have held, based on the aforementioned narrations, that it is recommended to recite aloud in it, as we have just mentioned. The majority have held that reciting quietly is recommended. Ibn Qudamah said:
“He recites quietly in the funeral prayer, both the recitation and the supplication. We do not know of any difference among the scholars in this.” End quote.
They based this on the hadith of Abu Umamah who said:
“The Sunnah in the funeral prayer is that the imam recites the Opening of the Book quietly after the first takbir.” The hadith is narrated by al-Nasa’i, and through him by Ibn Hazm in al-Muhalla (vol. 5, p. 129).
Al-Nawawi said in Sharh al-Muhadhdhab:
“Al-Nasa’i narrated it with a chain according to the conditions of the two Sahihs, and said:
‘This Abu Umamah is a Companion.’” End quote.
And what al-Shafi’i narrated in al-Umm (vol. 1, p. 239), and al-Bayhaqi (vol. 4, p. 39) through his route, from Mutarrif ibn Mazin from Ma’mar from al-Zuhri who said:
“Abu Umamah ibn Sahl informed me that a man from the Companions of the Prophet (sallallahu alayhi wa sallam) informed him that the Sunnah in the funeral prayer is that the imam says the takbir, then recites the Opening of the Book quietly to himself after the first takbir.” The narration is weakened due to Mutarrif, but al-Bayhaqi strengthened it with what he narrated in al-Ma’rifah and al-Sunan from Ubaydullah ibn Abi Ziyad al-Rasafi from al-Zuhri with the same meaning, and with what al-Hakim (vol. 1, p. 359) and al-Bayhaqi (vol. 4, p. 42) through his route narrated from Shurayhbil ibn Sa’d who said:
“I attended Abdullah ibn Abbas praying over a funeral at al-Abwa. He said the takbir, then recited Umm al-Qur’an (al-Fatihah) raising his voice with it, sent blessings upon the Prophet (sallallahu alayhi wa sallam), then said:
‘O Allah, Your servant and the son of Your servant...’ (the hadith). At the end, he turned and said:
‘O people, I only recited aloud so that you may know it is Sunnah.’” Al-Hafiz said in al-Fath:
“Shurayhbil’s reliability is disputed.” End quote.
Ibn al-Jarud narrated in al-Muntaqa from Zayd ibn Talhah al-Taymi who said:
“I heard Ibn Abbas recite over a funeral the Opening of the Book and a surah, and he recited aloud, and said:
‘I only recited aloud to teach you that it is Sunnah.’”
Some have said that one has the choice between reciting aloud and quietly. Some of the Shafi’is said:
“He recites aloud at night, as in the night prayers, and quietly during the day.”
Our Shaykh, in Sharh al-Tirmidhi, said regarding the statement of Ibn Abbas:
“I only recited aloud so that you may know it is Sunnah,” indicates that his reciting aloud was for teaching, not to show that reciting aloud is Sunnah. He said:
“As for the statement of some Shafi’is that he recites aloud at night as in the night prayers, I have not found any narration indicating this.” End quote.
This indicates that the Shaykh inclined to the view of the majority that reciting quietly is recommended.
Furthermore, the narration of Ibn Abbas in al-Nasa’i with the wording:
“He recited the Opening of the Book and a surah,” indicates the legitimacy of reciting a surah along with al-Fatihah in the funeral prayer.
Al-Shawkani said:
“There is no way to avoid accepting this, for it is an addition coming from a sound source.”
I say:
It is also indicated by what Ibn Hazm mentioned in al-Muhalla (vol. 5, p. 129), quoting from Muhammad ibn Amr ibn ‘Ata that al-Miswar ibn Makhramah prayed over a funeral, and in the first takbir recited the Opening of the Book and a short surah, raising his voice with them. When he finished, he said:
“I do not ignore that this prayer could be mute (i.e., without recitation), but I wanted to teach you that there is recitation in it.”
(Mir’at al-Mafatih, vol. 2, p. 478)
The summary of this lengthy statement of Hazrat Maulana Shaykh al-Hadith Ubaidullah Mubarakpuri rahimahullah is that reciting Surah al-Fatihah in the funeral prayer is obligatory, as is the view of Imam al-Shafi’i, Ahmad, Ishaq, and others.
All of them are unanimous that Surah al-Fatihah is the prayer itself, and it is mentioned in the hadith that there is no prayer without reciting Surah al-Fatihah.
Thus, the funeral prayer is also included in this generality, and there is no sound evidence to exclude it from this generality. Also, the funeral prayer is a prayer in which standing is obligatory.
Therefore, recitation is obligatory in it just as in other prayers, and also because there is an explicit command to recite in it.
As narrated in Ibn Majah from Umm Sharik that the Messenger of Allah (sallallahu alayhi wa sallam) commanded us to recite Surah al-Fatihah in the funeral prayer.
Although there is some weakness in the chain of this hadith, it is valid to use it as evidence due to other supporting proofs and witnesses. Similarly, in al-Tabarani, it is narrated from Umm ‘Afif that the Messenger of Allah (sallallahu alayhi wa sallam) commanded us to recite Surah al-Fatihah in the funeral prayer, and a command is for obligation.
It is also narrated in al-Tabarani from Asma bint Yazid that the Prophet (sallallahu alayhi wa sallam) said: “When you pray over a funeral, recite Surah al-Fatihah.”
Among the later Hanafis, Maulana Hasan Sharnbalani rahimahullah wrote a treatise on this issue named “al-Nazm al-Mustatab li-Hukm al-Qira’ah fi Salat al-Janazah bi-Umm al-Kitab,”
in which he established that reciting Surah al-Fatihah in the funeral prayer is better than not reciting it, and there is no evidence for its dislike.
Similarly, Maulana Abdul Hayy Lakhnawi rahimahullah wrote in his works ‘Umdat al-Ri’ayah, al-Ta’liq al-Mumajjad, and Imam al-Kalam, etc.
Then, evidence for reciting Surah al-Fatihah aloud in the funeral prayer is taken from the hadith of Ibn Abbas, which is a clear proof that he recited it aloud,
so much so that the followers heard it, and even clearer is the narration reported by al-Nasa’i.
The narrator states that he prayed the funeral prayer behind Ibn Abbas (radi Allahu anhu).
He recited Surah al-Fatihah and a surah aloud so that we heard it.
When he finished, I took his hand and asked him about this issue.
He replied, “Indeed, this is Sunnah and truth.” The hadith of ‘Awf ibn Malik is also evidence for reciting the supplications aloud in the funeral prayer,
as he memorized those supplications by hearing the Prophet (sallallahu alayhi wa sallam) recite them aloud behind him, and even clearer is the hadith of Wathilah.
And the scholars have differed on this matter.
Some, based on the aforementioned narrations, have considered reciting aloud to be recommended, as we have just mentioned.
The majority have considered reciting quietly to be recommended.
The evidence of the majority is the hadith of Abu Umamah, in which reciting quietly is described as Sunnah.
It is narrated by al-Nasa’i.
Allamah Ibn Hazm rahimahullah in al-Muhalla, Imam al-Shafi’i in al-Umm, and al-Bayhaqi and others have also narrated that a Companion of the Messenger of Allah (sallallahu alayhi wa sallam) said that Surah al-Fatihah should be recited quietly in the funeral prayer.
Shurayhbil ibn Sa’d says that he participated in a funeral prayer behind Abdullah ibn Mas’ud (radi Allahu anhu) at Abwa.
He recited Surah al-Fatihah, salutations, and supplications aloud, then said, “I would not have recited aloud except to teach you that this is Sunnah.”
And in al-Muntaqa of Ibn Jarud, it is narrated that Zayd ibn Talhah al-Taymi prayed the funeral prayer behind Abdullah ibn Abbas (radi Allahu anhu), in which he recited Surah al-Fatihah and a surah aloud, and afterwards said, “I only recited aloud to teach you that this is Sunnah.”
Some scholars say that one has the choice between reciting aloud and quietly.
Some Shafi’is have said that at night, one should recite aloud in the funeral prayer, and during the day, quietly.
Our Shaykh, Maulana Abdur Rahman Mubarakpuri rahimahullah, is inclined to the view of the majority and states that reciting quietly is recommended, and the narrations from al-Nasa’i regarding Abdullah ibn Abbas (radi Allahu anhu) are evidence that reciting Surah al-Fatihah along with a surah in the funeral prayer is legislated.
Al-Miswar ibn Makhramah recited Surah al-Fatihah and a short surah in the first takbir of a funeral prayer.
Then he said, “I recited aloud so that you may know that there is recitation in this prayer as well, and that this prayer is not mute (i.e., without recitation).”
End of the summarized content.
The conclusion is that reciting Surah al-Fatihah along with a surah in the funeral prayer is necessary.
Hazrat Qadi Thanaullah Panipati Hanafi rahimahullah, in his famous book Ma La Budda Minhu, also included his will,
in which he stated that his funeral prayer should be led by someone who recites Surah al-Fatihah in it.
Thus, it is established that this is the chosen position of all the people of truth.
The Fatwa of the Hanafi Scholars! The respected author of Tafhim al-Bukhari has stated on this occasion that according to the Hanafis, reciting Surah al-Fatihah in the funeral prayer is also permissible.
Since it is more comprehensive than other supplications, what harm can there be in reciting it?
However, it should be recited with the intention of supplication and praise, not with the intention of recitation.
(Tafhim al-Bukhari, vol. 5, p. 122)
What the respected author has stated at the end is not correct, because in the aforementioned narrations it is established that it is recited as recitation.
Therefore, what need remains for this distinction?
In any case, may Allah grant that our respected Hanafi brothers begin reciting Surah al-Fatihah in the funeral prayer; this too would be a good initiative.
In the above narrations, when Ibn Abbas (radi Allahu anhu) and others said that this is Sunnah and truth, Hazrat Maulana Shaykh al-Hadith (may Allah preserve him) explained it as follows:
And what is meant by Sunnah is:
The well-known way from him (sallallahu alayhi wa sallam), not what is contrasted with obligation, for that is a later technical usage. Al-Ashraf said:
The feminine pronoun refers to the recitation of al-Fatihah, and what is meant by Sunnah is not that it is not obligatory, but rather what is contrasted with innovation, i.e., it is a transmitted way. Al-Qastallani said:
It, i.e., the recitation of al-Fatihah in the funeral prayer, is Sunnah, i.e., a way of the Lawgiver, so it does not contradict its being obligatory. And it is known that the statement of a Companion:
“From the Sunnah is such-and-such,” is considered a marfu’ (attributed to the Prophet) hadith by most scholars. Al-Shafi’i said in al-Umm:
“The Companions of the Prophet (sallallahu alayhi wa sallam) would not say ‘Sunnah’ except for the Sunnah of the Messenger of Allah (sallallahu alayhi wa sallam), if Allah wills.” End quote. (Mir’at al-Mafatih, p. 477)
That is, here by the word Sunnah is meant the well-known way of the Prophet (sallallahu alayhi wa sallam), not the Sunnah that is contrasted with obligation.
This is a technical term used in common parlance; it is not meant that it is not obligatory, but rather the Sunnah that is contrasted with innovation is meant.
That is, it is a transmitted way, and al-Qastallani said that reciting Surah al-Fatihah in the funeral prayer is Sunnah, i.e., the way of the Lawgiver, and this does not contradict its being obligatory.
Imam al-Shafi’i rahimahullah said in al-Umm that the Companions used the word Sunnah for the way of the Messenger of Allah (sallallahu alayhi wa sallam).
In the statements of the Companions, the word Sunnah is also used for a marfu’ hadith.
In any case, what is meant by Sunnah here is that reciting Surah al-Fatihah in the prayer is the Prophetic way, and it is obligatory, such that the prayer is not valid without it, as detailed above.

Hadith Commentary:
(1)
Since the funeral prayer (janazah) is also a prayer (salah), as has already been clarified in Chapter 56, it is therefore necessary to recite Surah al-Fatihah in it just as in other prayers. As the Messenger of Allah (sallallahu alayhi wa sallam) said:
“Whoever does not recite Surah al-Fatihah, his prayer is not valid.”
(Sahih al-Bukhari, al-Adhan, Hadith: 756)
Furthermore, the aforementioned hadith explicitly states that reciting Surah al-Fatihah in the funeral prayer is the practice of the Messenger of Allah (sallallahu alayhi wa sallam).
In Sunan al-Nasa’i, it is mentioned that Ibn Abbas (radi Allahu anhu) recited Surah al-Fatihah along with another surah in the funeral prayer and recited aloud. When he finished, he said that this is the Sunnah and the truth.
(Sunan al-Nasa’i, al-Jana’iz, Hadith: 1989)
This narration also makes it clear that Surah al-Fatihah should be recited after the first takbir.

(2)
This narration also shows that it is permissible to recite the funeral prayer aloud.
This position is also supported by a hadith narrated from Awf ibn Malik (radi Allahu anhu), who said that the Messenger of Allah (sallallahu alayhi wa sallam) led the funeral prayer and we memorized the supplication he recited.
(Musnad Ahmad: 23/6)
The funeral prayer may also be recited in a low voice.
As Abu Umamah ibn Sahl (radi Allahu anhu) said:
The Sunnah in the funeral prayer is that after the first takbir, Surah al-Fatihah should be recited quietly, then three takbirs should be said, and with the last takbir, the salam should be given.
(Sunan al-Nasa’i, al-Jana’iz, Hadith: 1991)
The majority of scholars hold the view that Surah al-Fatihah should be recited in the funeral prayer. However, Imam Malik and the scholars of Kufa are of the opinion that there is no recitation in the funeral prayer, though the Hanafis have declared the recitation of Surah al-Fatihah as a supplication to be legislated.

(4)
In one hadith, the complete method of the funeral prayer is described in these words:
“The Sunnah method in the funeral prayer is that the imam says the takbir, then recites Surah al-Fatihah, after that sends blessings upon the Messenger of Allah (sallallahu alayhi wa sallam), then after the third takbir, sincerely supplicates for the deceased.”
(al-Mustadrak lil-Hakim: 1/360)
After the fourth takbir, the salam should be given.