Imam al-Bukhari: Mujtahid or Shafi‘i Follower?

Compiled by: Abu Hamza Salafi

Imam al-Bukhari: Mujtahid Mutlaq or Shafi‘i Muqallid?

A prejudiced Hanafi writer claims that Imam al-Bukhari رحمه الله was Shafi‘i in jurisprudence. To support this claim, he cites statements from Taj al-Din al-Subki, Nawab Siddiq Hasan, al-Qastallani, Ibn Taymiyyah, Ibn al-Qayyim, Shah Waliullah al-Dihlawi, and others, attempting to portray Imam al-Bukhari not as a Mujtahid Mutlaq but as a “Shafi‘i muqallid.”

The Response

This allegation is, in reality, a failed attempt to diminish the scholarly rank and juristic authority of Imam al-Bukhari.

① Firstly

Imam al-Bukhari’s works—especially al-Jami‘ al-Sahih—and his meticulous arrangement of jurisprudential chapter headings, along with deriving multiple rulings from a single hadith, are definitive proof that he was a Mujtahid Mutlaq.

② Secondly

The statements used to attribute Shafi‘i affiliation to him are either products of partisan bias or have been quoted out of context.

③ Thirdly

Leading scholars—including Ahl al-Hadith, Shafi‘i scholars, and even some Hanafi authorities—have explicitly affirmed that Imam al-Bukhari was a Mujtahid Mutlaq.

❖ The Argument of al-Subki and Abu ‘Asim al-‘Abbadi

The Hanafi writer first cites Taj al-Din al-Subki (d. 771 AH) and Abu ‘Asim al-‘Abbadi al-Shafi‘i (d. 468 AH):

They state that Imam al-Bukhari studied jurisprudence under al-Za‘farani, Abu Thawr, and al-Karabisi—who were students of Imam al-Shafi‘i—therefore al-Bukhari was Shafi‘i in madhhab.

Reference: Tabaqat al-Shafi‘iyyah al-Kubra 2/214

Response

① Abu ‘Asim al-‘Abbadi merely stated that Imam al-Bukhari heard from scholars who were students of Imam al-Shafi‘i. This does not necessitate that al-Bukhari himself was a Shafi‘i muqallid.

② Al-Subki also mentioned Imam Ahmad ibn Hanbal, Imam Dawud al-Zahiri, and Imam Muhammad ibn Jarir al-Tabari in his Tabaqat. All of them were founders of independent schools. So why single out Imam al-Bukhari as a Shafi‘i muqallid?

③ Al-Subki himself acknowledged that Imam al-Bukhari did not narrate directly from Imam al-Shafi‘i in his Sahih but transmitted through his students.

④ Therefore, describing him as “Shafi‘i in madhhab” is merely a terminological attribution, meaning that some of his juristic opinions corresponded with those of Imam al-Shafi‘i. This is not taqlid but ijtihadi agreement.

❖ Refutation of the Attributions to Nawab Siddiq Hasan and al-Qastallani

1️⃣ Nawab Siddiq Hasan

The claim:

Nawab Siddiq Hasan Bhopali mentioned Imam al-Bukhari among the Shafi‘is in Abjad al-‘Ulum.

Response

Nawab Siddiq Hasan (d. 1307 AH) quoted this statement from the Hanafi author Muhammad ibn Qutb al-Din al-Azniki al-Rumi (d. 885 AH) in Madinat al-‘Ulum, and then refuted it.

He clarified:

“The authors of Tabaqat, out of partisanship, included individuals in their lists who were not their followers. The truth is that these Imams (Bukhari, Muslim, Tirmidhi, etc.) were not muqallids; rather, they were mujtahids who adopted the strongest opinions after reflection and analysis.”

Reference: Abjad al-‘Ulum 3/126

✦ Hence, Nawab Siddiq Hasan did not declare Imam al-Bukhari to be Shafi‘i; rather, he refuted the notion of him being a muqallid.

2️⃣ Al-Qastallani

It was claimed that Imam al-Qastallani (d. 923 AH) wrote in Irshad al-Sari that Imam al-Bukhari was Shafi‘i.

Response

This is completely false. Nowhere in Irshad al-Sari does al-Qastallani describe Imam al-Bukhari as a “Shafi‘i muqallid.”

✦ He only mentioned that some of al-Bukhari’s juristic conclusions align with the Shafi‘i position, as evident in his chapter headings. He never labeled him a Shafi‘i muqallid.

❖ Refutation of Attributions to Ibn Taymiyyah, Ibn al-Qayyim, and Shah Waliullah

1️⃣ Ibn Taymiyyah

The claim:

“According to Ibn Taymiyyah, Imam al-Bukhari, Muslim and other hadith scholars were muqallids of al-Shafi‘i or of the Hanbali [school].”

Reference: Majmu‘ al-Fatawa 25/232

Response

The actual statement of Ibn Taymiyyah is:

“Imam al-Bukhari and Abu Dawud were both Imams in fiqh and among the people of ijtihad, and they were not followers of any single scholar. As for Muslim, Tirmidhi, Nasa’i, Ibn Majah, and others, they were upon the methodology of Ahl al-Hadith—not followers of any single scholar, nor were they Mujtahid Mutlaq.”

Reference: Majmu‘ al-Fatawa 25/232

✦ Thus, Ibn Taymiyyah explicitly declared Imam al-Bukhari to be a Mujtahid Mutlaq, not a muqallid.

2️⃣ Ibn al-Qayyim

The claim:

“Ibn al-Qayyim wrote that Imam al-Bukhari was Hanbali.”

Reference: I‘lam al-Muwaqqi‘in 3/543

Response

Imam al-Bukhari (d. 256 AH) and Imam Ahmad ibn Hanbal (d. 241 AH) were contemporaries. Ibn al-Qayyim (d. 751 AH) inadvertently mentioned such wording in one place, but his own other explicit statements contradict this attribution.

In I‘lam al-Muwaqqi‘in, Ibn al-Qayyim described a muqallid as “ignorant.” If he believed Imam al-Bukhari to be a Hanbali muqallid, he would never have used such terminology.

✦ Therefore, this attribution is merely a scribal error or an error of understanding, which the prejudiced Hanafi makes into his evidence.

3️⃣ Shah Waliullah al-Dihlawi

The claim:

“Shah Waliullah declared Imam al-Bukhari to be Shafi‘i.”

Reference: Al-Insaf p.50

Response

Shah Waliullah (d. 1176 AH) stated:

“Ahl al-Hadith are sometimes attributed to a madhhab due to frequent agreement, such as Imam al-Nasa’i and al-Bayhaqi being called Shafi‘i.”

Reference: Hujjat Allah al-Balighah 1/152

He further wrote:

“Imam al-Bukhari’s method of ijtihad was close to that of Imam al-Shafi‘i; therefore, he agreed with him in some issues and differed in others.”

Reference: Al-Insaf

✦ Thus, Shah Sahib made it clear that “this attribution is merely due to agreement, not due to taqlid.”

❖ Testimony of Imam al-Tahawi and Other Hadith Scholars

① Imam al-Tahawi (d. 321 AH)

Imam Abu Ja‘far al-Tahawi (d. 321 AH), though himself from a Hanafi background, said:

“Abu ‘Ubayd ibn Jurthumah used to discuss legal issues with me. One day I answered a question of his, and he said: ‘This is the view of Abu Hanifah.’ I said: ‘Must I say whatever Abu Hanifah said?’ He said: ‘I thought you were a muqallid.’ I said: ‘Taqlid is done only by the disobedient and the unintelligent.’”

Reference: Lisan al-Mizan 4/167, Sharh ‘Uqud Rasm al-Mufti

✦ This makes clear that the great jurists and hadith scholars were not muqallids themselves but practised ijtihad. The same is true of Imam al-Bukhari.

② Ibn Taymiyyah

“Imam al-Bukhari and Abu Dawud were Imams in fiqh and among the people of ijtihad.”

Reference: Majmu‘ al-Fatawa 25/232

③ Hafiz al-Dhahabi

“Muhammad ibn Isma‘il al-Bukhari was an Imam, a Hafiz, an authority, a leader in fiqh and hadith, a mujtahid, and unmatched in piety.”

Reference: Al-Kashif 3/33

④ Tahir al-Jaza’iri

“Al-Bukhari and Abu Dawud were Imams in fiqh and among the people of ijtihad.”

Reference: Tawjih al-Nazar 2/804

⑤ Mulla ‘Ali al-Qari (Hanafi)

“Imam al-Bukhari possessed immense strength in ijtihad and deduction and was a formidable mujtahid.”

Reference: Mirqat al-Mafatih

⑥ Ibrahim al-Sindi (Hanafi)

“Imam al-Bukhari was a Mujtahid Mutlaq like Abu Hanifah, al-Shafi‘i, Malik, and Ahmad.”

Reference: Ma Tamassu Ilayh al-Hajah

⑦ Al-‘Allamah Isma‘il al-‘Ajluni (Shaykh of ‘Allamah al-Shami)

“Ibn Taymiyyah and al-Sakhawi explicitly affirmed that Imam al-Bukhari was a Mujtahid Mutlaq.”

Reference: Al-Fawa’id al-Darari fi Tarjamat al-Imam al-Bukhari

❖ Testimonies of Deobandi and Contemporary Scholars

① Mawlana Rashid Ahmad Gangohi (Deobandi)

“Imam al-Bukhari, in my view, is an independent mujtahid. His being a jurist and a mujtahid becomes clear when one studies his chapter headings with careful insight.”

Reference: Lami‘ al-Darari Sharh Sahih al-Bukhari

② Shaykh al-Hadith Mawlana Salimullah Khan (Deobandi)

“Imam al-Bukhari was a Mujtahid Mutlaq, not a muqallid of anyone, and this is the view I have adopted.”

Reference: Kashf al-Bari

③ Mufti Rafi‘ ‘Uthmani (Deobandi)

“Imam al-Bukhari is unquestionably a Mujtahid Mutlaq. His book is a just witness to this. The commonly known attribution of him being Shafi‘i is because his position agrees with al-Shafi‘i’s in the well-known issues, but this agreement is no proof that he was a Shafi‘i.”

Reference: Dars Muslim

④ Zakariyya Kandhalawi (Deobandi)

“Imam al-Bukhari was firmly a mujtahid. Although the Shafi‘i jurists listed him in the Tabaqat of the Shafi‘is, al-Bukhari is as much opposed to the Shafi‘is as he is displeased with the Hanafis, and even somewhat more.”

Reference: Taqrir Bukhari Sharif

⑤ ‘Abd al-Hayy al-Lucknawi (Hanafi)

“Imam al-Bukhari, Abu Thawr, and Dawud al-Zahiri were Mujtahid Mutlaq after the four Imams. The claim that ijtihad ended with the four Imams is false and rejected.”

Reference: Al-Jami‘ al-Saghir wa Sharhuhu al-Nafi‘ al-Kabir