Nasai

Regarding slaves, the Hanafi scholars are also in agreement with the rest of the majority of scholars that there is no zakat on a slave kept for service, because there is no zakat on anything that is for personal necessity. However, there is zakat on slaves kept for trade, because they are considered trade goods. The same principle applies to horses, but the Hanafi scholars, without any reasonable justification, have changed the ruling regarding horses.

This hadith and other ahadith explicitly negate the obligation of zakat on horses; therefore, the correct view is that if slaves and horses are kept for service, there is no zakat on them. That is why no nisab (minimum threshold) has been prescribed for them. Furthermore, it is an established principle that there is no zakat on items that fall under personal necessities. However, the Hanafis, by reasoning from general statements or weak narrations, have negated these explicit ahadith and established zakat on horses (even if there is only one), which is not appropriate in any respect. Nevertheless, there is definitely zakat on horses and slaves kept for trade, because they are included among trade goods. Similarly, the mention of sadaqat al-fitr (obligatory charity at the end of Ramadan) for slaves is found in authentic narrations. However, apart from zakat, there may be other rights related to horses, such as: using them in jihad, temporarily lending them to someone for riding, or leaving them for breeding, etc. Other narrations should be interpreted in light of these rights.

Hadith Commentary:
The well-researched position of the Ahl al-Hadith is that there is absolutely no obligatory zakat in slaves and horses, even if they are for trade.
However, Ibn Mundhir has transmitted consensus (ijma‘) on the matter that if they are for trade, then zakat is obligatory on them.
The fundamental principle is that zakat is only obligatory on those categories which the Prophet (sallallahu alayhi wa sallam) has specified.
That is, among livestock: camels, cows, oxen, and goats; among monetary wealth: gold and silver; among grains: wheat, barley, and millet; and among fruits: dates and dried grapes (raisins). Other than these, there is no zakat on any other wealth, even if it is for trade and commerce. The consensus (ijma‘) that Ibn Mundhir has transmitted to the contrary is not correct.
When the apparent situation is this, and the Ahl al-Hadith themselves differ on this issue, then how can there be consensus (ijma‘)?
And the hadith of Abu Dawud and the hadith of Dar Qutni, in which it is reported that the Prophet (sallallahu alayhi wa sallam) commanded zakat on wealth kept for sale, or that there is zakat on cloth, are weak (da‘if).
They are not suitable as proof.
And in the Qur’anic verse: ﴿خُذ مِن أَموَالَهِم صَدقَة﴾ (“Take charity from their wealth” — ), by “wealth” (amwal) is meant only those types of wealth whose zakat has been explicitly mentioned in the hadith.
This is the research of Imam Shawkani, and Sayyid Allamah has supported it.
On this basis, zakat will not be obligatory on jewels, pearls, coral, rubies, diamonds, and hundreds of other commercial items such as horses, vehicles, books, and paper.
However, since the four Imams (a’immah arba‘ah) and the majority of scholars (jumhur ‘ulama) have held the obligation of zakat on commercial goods, therefore, caution and piety (taqwa) dictate that zakat should be given from them.
(Wahidi)

Hadith Commentary:
It is stated in Sahih Muslim that for a slave, there is no zakat except for zakat al-fitr.
(Sahih Muslim, Kitab al-Zakat, Hadith: 2276(982))

This means that the absolute narration of Sahih Bukhari must be restricted by the narration regarding zakat al-fitr. Similarly, if slaves are kept for trade and the income obtained from them accumulates and a year passes over it, then zakat must be given on them just like other trade goods. Furthermore, at the time of giving zakat, the value of these slaves must also be assessed, added to the income, and then zakat must be given at the rate of two and a half percent.

And Allah knows best.

Hadith Commentary:
(1)
Horses that are kept for riding and slaves that are kept for service are not subject to zakat; however, those horses that are kept for the purpose of trade, it is obligatory to pay zakat on their income.

(2)
Imam Bukhari rahimahullah has most likely alluded to the narration reported by Ali radi Allahu anhu, in which the Messenger of Allah sallallahu alayhi wa sallam said:
“I have exempted horses and slaves from zakat, but you must certainly pay zakat on silver and the like.”
(Sunan Abi Dawud, Zakat, Hadith: 1574) (2)
But the meaning of this hadith is that zakat is not obligatory on horses at a fixed rate as it is on camels, cows, and goats; however, if they are kept for the purpose of trade, then zakat must be paid on their income, as Ibn al-Mundhir has transmitted consensus (ijma‘) on this.
(Fath al-Bari: 3/412)

Hadith Commentary: Benefits and Issues: According to the majority of the early scholars (jumhur ulama as-salaf), there is no charity (zakat) due on slaves and horses kept for the necessities of one’s household. If they are kept for trade, then—except for the Zahiri school—according to all, zakat is due on their value. According to Imam Abu Hanifah rahimahullah, zakat is due on horses if both male and female are kept for breeding purposes; in that case, one dinar (equivalent to 4/1/2 mithqal of gold) is due annually on each. And if only one gender is kept, then zakat is to be given at the rate of two and a half percent (2.5%) of their value, or one dinar or ten dirhams as zakat on each.

1:
The Zahiri school has deduced from the generality of this hadith that there is absolutely no obligatory zakat on horses and slaves, even if they are intended for trade.
However, this is not correct.
If horses and slaves are for trade, then zakat is obligatory on them by consensus (ijma‘), as Ibn al-Mundhir and others have transmitted.
Therefore, consensus (ijma‘) will serve as a specification (takhsis) for the generality of this hadith.

1594. Commentary: If these are for personal use, then there is no zakat on them. However, if they are for the purpose of trade, then zakat should be given.

1595. Commentary: It has already been mentioned in the benefits of Hadith 1574 that there is no zakat on them when they are for personal use. However, if they are for trade, then zakat will be obligatory on them.

Benefit:
This issue has also been discussed in Hadith: 1790.

Takhrij al-Hadith: [وأخرجه مسلم 982، من حديث مالك به .]
Jurisprudential Points:
➊ No zakat is obligatory on any horses or slaves that a person owns.
➋ Regarding horses, see: [الموطأ حديث: 178، 215، والبخاري 2860، 2849، ومسلم 1871/96]
➌ It is understood that certain things are exempted from the ruling of zakat by specific command.
➍ The general can be specified by a particular evidence.

Benefit:
This hadith proves that there is no zakat on slaves and horses, meaning that a slave kept for personal service and a horse kept specifically for riding are not subject to any kind of zakat. However, if they are kept for trade, then zakat will be obligatory on them.
This is the position of the majority of scholars and most jurists. For further details regarding zakat on horses, see: [سنن ابوداود ، الزكاة ، باب فى زكاة السائمة ، حديث : 1574 ۔ طبع دارالسلام ، لاهور]

Benefit:
It is established from this hadith that there is no zakat on slaves and horses. Using this hadith as evidence, it is also established that there is no zakat on personal vehicles and personal residences, etc. However, if there are such horses that are used for rental purposes or are bought and sold, similarly, if houses and vehicles are for rental purposes or are bought and sold, then zakat is due on their income, if it reaches the nisab (minimum threshold).