A Judge Must Not Pass Judgment in a State of Anger
✍ Written by: Imran Ayyub Lahori
◈ Prohibition of Judging in Anger
Abu Bakr (RA) narrated that the Messenger of Allah ﷺ said:
لا يقضيـن حـاكـم بين اثنين وهو غضبان
“A judge must never decide between two people while he is angry.”
[Bukhari: 7158, Kitab al-Ahkam: Bab hal yaqdi al-qadi aw yufti wa huwa ghadban?; Muslim: 1717; Abu Dawud: 3589; Tirmidhi: 1334; Nasa’i: 8/237; Ibn Majah: 2316; Ahmad: 5/36; Bayhaqi: 10/104; Ibn Hibban: 5063]
◈ Scholarly Explanation
✔ Imam Shawkani (رحمه الله):
The absence of any contextual evidence diverting the ruling of this Hadith towards mere dislike is proof that judging in a state of anger is haram.
[Nayl al-Awtar: 5/366]
As for the Hadith in which the Messenger of Allah ﷺ judged between an Ansari and Zubair (RA) while in some anger:
[Bukhari: 2361]
This does not contradict the earlier Hadith, because unlike others, the Prophet ﷺ was ma‘sum (protected from error) in both his anger and pleasure.
[Nayl al-Awtar: 5/366; al-Rawdah al-Nadiyyah: 2/545]
◈ Rulings Regarding Judgments Made in Anger
Scholars have differed on whether a judgment made in anger is valid or not:
① The Majority:
If the judgment accords with truth, then it will be enforced.
② Some Hanbalis:
A judgment made in anger is not enforceable.
③ Other Scholars (Detailing):
If the judge becomes angry after the ruling has been completed, the judgment remains valid. But if the anger occurred before or during the ruling, then it is invalid.
[A‘lam al-Muwaqqi‘in: 4/227; Nayl al-Awtar: 5/366]
◈ Preferred View (الراجح)
The detailed distinction is the most correct:
- If anger arises after the judgment, the ruling stands valid.
- If anger arises before or during the process of judgment, the ruling is invalid.
[Fath al-Bari: 15/36]
