Recitation of Sūrah al-Fātiḥah in Funeral Prayer and the Invalidity of Abrogation Claims

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Excerpt Source: Namāz-e-Janāzah mein Sūrah al-Fātiḥah: Farḍ, Mustaḥabb, yā Makrūh Taḥrīmī?
By: Dr. Ḥāfiẓ Abū Yaḥyā Nūrpūrī

❖ The Command of the Prophet ﷺ

✿ Narration of ʿUmm Shurayk رضي الله عنها

The noble Companion, Sayyidah Umm Shurayk رضي الله عنها said:

أمرنا رسول الله صلى الله عليه وسلم أن نقرأ على الجنازة بفاتحة الكتاب
“The Messenger of Allah ﷺ commanded us to recite Sūrah al-Fātiḥah in the funeral prayer.”

Reference: Sunan Ibn Mājah: 1496; al-Tārīkh al-Kabīr of al-Bukhārī: 3/22

Chain Status: Ḥasan (Sound) – Graded by al-Buṣayrī (Miṣbāḥ al-Zujājah: 1/267) and Maulānā Zafar Aḥmad Thānvī (Iʿlāʾ al-Sunan: 6/2567)

Imāms like al-Tirmidhī, Ibn Mājah, Ibn al-Jawzī, al-Nawawī, and Ibn Ḥajar have cited this ḥadīth in the context of reciting al-Fātiḥah in the funeral prayer. Some scholars, however, have raised doubts regarding its authenticity, which we now analyze.

◈ Critique of the Narrators and Defense of Their Reliability

① Ḥammād ibn Jaʿfar – Reliable According to Major Scholars

  • Imām Yaḥyā ibn Maʿīn رحمه الله: “Ḥammād ibn Jaʿfar al-Baṣrī is trustworthy.”
    (al-Jarḥ wa al-Taʿdīl: 3/134)
  • Imām Ibn Shāhīn رحمه الله and Imām Ibn Ḥibbān رحمه الله have also graded him as thiqah (reliable).

As for the criticism by Abū al-Fatḥ al-Azdī labeling him as weak:

  • This statement is unsubstantiated and thus not credible.
  • Abū al-Fatḥ al-Azdī himself is a discredited narrator and unreliable in matters of jarḥ and taʿdīl.
    (Tārīkh Baghdād: 2/243–244, Tārīkh al-Islām: 26/564)

Furthermore, Ibn ʿAdī’s statement regarding Ḥammād being munkar al-ḥadīth is speculative and may be due to confusion with another narrator Ḥammād ibn Jaʿfar al-Rāzī, as explained by Ibn Ḥajar.

② Shahr ibn Ḥawshab – Considered Ḥasan al-Ḥadīth by the Majority

  • Declared trustworthy by:
    Imām Aḥmad, Ibn Maʿīn, Abū Zurʿah, al-ʿAjlī, al-Bukhārī, Abū Ḥātim, al-Tirmidhī, etc.
  • Ibn al-Qaṭṭān al-Fāsī: All criticisms against him are unsubstantiated or irrelevant. (Bayān al-Wahm wal-Īhām: 3/321)
  • Imām al-Nawawī: Majority have declared him trustworthy; the criticisms are not valid causes of rejection. (al-Majmūʿ: 1/370)
  • al-Dhahabī: Marked “ṣaḥ” next to his biography, indicating his preference for accepting him.
  • al-Buṣayrī:

    “His ḥadīth is ḥasan.” (Majmaʿ al-Zawāʾid: 10/108)
    “He and ʿAbd al-Ḥamīd ibn Bahrām are both trustworthy; the criticisms do not invalidate them.” (Majmaʿ al-Zawāʾid: 1/222)

Thus, this ḥadīth is ḥasan in its chain, as even acknowledged by Zafar Aḥmad Thānvī.

❖ Analyzing the Objections Against the Ḥadīth of Umm Shurayk رضي الله عنها

① Objection: She is an Unknown Woman (Majhūlah)

Response:

  • It is accepted among the scholars that being an unknown Companion is not a flaw affecting reliability.
  • The statement of Umm Shurayk is supported by other Companions such as Ibn ʿAbbās and Abū Umāmah ibn Sahl, who also recited al-Fātiḥah in janāzah and called it a Sunnah.
  • Once the chain is accepted as ḥasan, questioning the narrator’s identity becomes irrelevant.
  • This narration agrees with other authentic narrations of Companions. Therefore, her report is in harmony, not contradiction.

② Objection: The Word “Commanded” Doesn’t Indicate Obligation

Response:

  • Saying the Prophet ﷺ’s command doesn’t entail obligation is problematic.
  • This reflects a dismissive approach to the Prophet’s ﷺ direct instructions.
  • Even if “command” is interpreted as non-binding, external evidence (such as the Prophet ﷺ saying:

    “There is no ṣalāh without al-Fātiḥah”)
    strengthens the view that reciting al-Fātiḥah is obligatory in all prayers, including janāzah.

③ Objection: The Chain Has Weaknesses

Response:

  • The criticisms are addressed and resolved above.
  • Even Zafar Aḥmad Thānvī accepted the chain as ḥasan, yet uses the claim of weakness to avoid acting upon it.
  • Comparison with the narration of Ibn ʿAbbās is flawed, as that narration also points to regular recitation of al-Fātiḥah in janāzah prayer and is not a negation of obligation.
  • As for the report by Abū Umāmah, which labels other janāzah actions (takbīr, durūd, duʿāʾ, salām) as “sunnah,” if “sunnah” is taken to mean “not farḍ,” then nothing in janāzah prayer would be farḍ—a conclusion even the Ḥanafī school does not accept.

④ Objection: The Command Was for Women Only

Claim by Amīn Okāṛwī:
How strange that women, upon whom janāzah prayer is not obligatory, are being commanded to recite al-Fātiḥah, but men are not.

Response:

  • The statement “The Prophet ﷺ commanded us” refers to all Muslims, not just women.
  • Such a narrow interpretation has no precedent in the understanding of earlier scholars.
  • For comparison: Sayyidah ʿĀʾishah رضي الله عنها said:

    “The Prophet ﷺ commanded us to perform ʿaqīqah.”
    Does that mean only women are instructed to do ʿaqīqah? Of course not.

  • ➎ Claim of Abrogation on the Hadith of Umm Shurayk رضي الله عنها

    Objection by Ameen Okarvi:
    Ameen Okarvi raised an objection and wrote:

    “It is mentioned in Ṣaḥīḥ al-Bukhārī:

    نهينا عن اتباع الجنائز – We were prohibited from following the funeral processions.

    Hence, there is no authentic narration proving that women would go to the graveyard to perform the funeral prayer. Therefore, those narrations pertain to a time when women used to perform the Janāzah prayer as well.”

    (Majmūʿah Rasāʾil, 1/263)

    Analysis

    ❖ Selective Quotation of Hadith

    Ameen Okarvi only quoted part of the hadith to support his claim.

    ✿ Complete wording of the hadith:

    نهينا عن اتباع الجنائز ولم يعزم علينا

    “We were prohibited from following funeral processions, but it was not made binding upon us.”

    [Ṣaḥīḥ al-Bukhārī: 1278, Ṣaḥīḥ Muslim: 938]

    This means that although women were discouraged, it was not strictly forbidden (ḥarām). Thus, claiming that the Hadith of Umm Shurayk رضي الله عنها was abrogated based on this is unjustified.

    ❖ The Janāzah Prayer Was Not Abrogated for Women

    The Sahābah رضي الله عنهم did not consider the funeral prayer prohibited for women.

    One example is from ʿĀʾishah رضي الله عنها:

    “ʿAbd al-Raḥmān bin Abī Bakr died in a place where he was residing. We carried him on our shoulders six miles away to Makkah. At that time, ʿĀʾishah رضي الله عنها was traveling. Upon returning, she said: ‘Show me his grave.’ When she was shown the grave, she performed Janāzah prayer at his grave.”

    [Muṣannaf Ibn Abī Shaybah: 3/41, ḥadīth 11939; Muṣannaf ʿAbd al-Razzāq: 3/815, ḥadīth 6539 | Chain: Ṣaḥīḥ]

    If it had been prohibited for women to pray Janāzah, ʿĀʾishah رضي الله عنها would not have done so.

    ❖ Testimony from Within the Ḥanafī School

    Ameen Okarvi used a narration from Umm ʿAṭiyyah رضي الله عنها to argue that women are entirely prohibited from funeral participation.

    But even the Ḥanafī scholar ʿAllāmah Badr al-Dīn al-ʿAynī (855 AH) wrote:

    “The statement ‘it was not enforced upon us’ implies that the prohibition is one of discouragement, not prohibition. Several narrations in this chapter indicate that this act (women following funerals) is permissible.”

    [ʿUmdat al-Qārī, Bāb Ittibāʿ al-Nisā’ al-Janāʾiz]

    So even major Ḥanafī authorities disagreed with Okarvi’s strict position.

    ❖ Hypocrisy in Methodology

    At one point, Mawlānā Ẓafar Aḥmad Thānawī said that the wording:

    “أمرنا رسول الله ﷺ” (The Messenger of Allah ﷺ commanded us)

    is not a proof of obligation.

    Yet, Ameen Okarvi uses:

    “نهينا” (We were forbidden)

    as evidence of prohibition and abrogation!

    This double standard contradicts fairness and objectivity.

    ➏ Claim of Abrogation of Sūrah al-Fātiḥah in Janāzah

    Okarvi’s Claim:

    “In the later period, the Prophet ﷺ neither instructed the recitation of al-Fātiḥah in Janāzah nor did he himself recite it. Therefore, even though these narrations are weak, they are possibly abrogated. Since the Ṣaḥābah and Tābiʿīn did not recite it, this strengthens the claim of abrogation.”

    (Majmūʿah Rasāʾil: 1/264)

    Analysis

    Ameen Okarvi made an unsupported claim that even men are prohibited from reciting Sūrah al-Fātiḥah in Janāzah.

    ❖ Habit of Declaring Hadiths “Abrogated”

    Shaykh al-Islām Ibn al-Qayyim al-Jawziyyah رحمه الله (751 AH) condemned this habit:

    “Many people misuse the claim of abrogation and ijmāʿ (consensus) to nullify authentic Sunnah. One should never abandon a sahih hadith unless there is a clear, authentic, and later abrogating evidence transmitted by the scholars. Declaring something abrogated without this is falsehood.”

    [Ṣalāh wa Aḥkām Tārikihā: p. 142]

    He explains that abrogation became a tool of escape when hadith contradicts one’s madhhab.

    ❖ Abrogation Cannot Be Claimed Against a Practiced Hadith

    If the Ṣaḥābah practiced a ḥadīth, it cannot be considered abrogated, because they were the most knowledgeable of Nāsikh and Mansūkh.

    Even Ḥanafī scholars agree:

    “The claim of abrogation is invalid when a ḥadīth was practiced by the companions. Through such actions, even additional rulings beyond the Qur’an can be established.”

    [Al-Hidāyah, Vol. 1, p. 24]

    “Such fatāwā from the noble companions came after the cessation of revelation. They were the most knowledgeable in the science of abrogation. Hence, the claim of abrogation is nullified.”

    [Badā’iʿ al-Ṣanā’iʿ: 1/16]

    ❖ Sahih Hadith Cannot Be Rejected Under Ḥanafī Principles

    The hadith of Umm Shurayk رضي الله عنها is ḥasan (good), and even Ẓafar Aḥmad Thānawī admitted this.

    ❖ Prophet’s ﷺ Own Practice in Janāzah Prayer

    Umm Shurayk رضي الله عنها said: The Prophet ﷺ used to recite al-Fātiḥah in Janāzah prayer.

    [Tārīkh al-Kabīr of al-Bukhārī: 3/22]
    Chain: Hasan

    Also, Asmā’ bint Yazīd رضي الله عنها narrated:

    “Recite al-Fātiḥah over the deceased.”

    [Tārīkh al-Kabīr by al-Bukhārī: 3/22 | al-Muʿjam al-Kabīr of al-Ṭabarānī: 413 | Chain: Hasan]

    ❖ To Abandon a Clear Command of the Prophet ﷺ

    The Prophet ﷺ explicitly commanded:

    “When you offer Janāzah, recite al-Fātiḥah.”

    Yet Okarvi says:

    “To declare al-Fātiḥah as fard in Janāzah without evidence is to include Satan’s part in prayer. One must avoid it completely.”

    (Majmūʿah Rasāʾil: 1/272)

    Such words oppose clear, authentic teachings of the Prophet ﷺ.

    ✅ Conclusion

    ✔ The claim that women cannot offer funeral prayers or that their hadiths have been abrogated is unfounded.
    ✔ The narrations of Umm Shurayk رضي الله عنها and Asmā’ bint Yazīd رضي الله عنها establish the Prophetic command and practice of reciting Sūrah al-Fātiḥah in Janāzah.
    ✔ The ḥadīth is ḥasan, accepted by scholars, and practiced by companions.
    ✔ Declaring such a hadith abrogated without proof is against the methodology of Ahl al-Ḥadīth, Imām Aḥmad, Imām al-Shāfiʿī, and even Ḥanafī Usūl.