Mufti 'Abdur Rahman Ibn Yusuf Mangera
The Messenger of Allah (salallahu alayhi wa sallam) laid great emphasis on the sunnah prayer of Fajr, saying, "It is more superior than the world and everything within it." (Sahih Muslim 1:151) Likewise, there are a number of narrations from which the importance of this sunnah prayer can be understood. This means that a person should ensure that is is performed prior to the fard prayer, since no sunnah prayer is permissible until after sunrise, once the fard prayer of Fajr is performed.
So what is one to do if he arrives lat to the masjid for Fajr, and finds the congregational prayer about to begin or already in progress? On the one hand, he remembers the emphasis regarding the sunnah prayer of Fajr, yet on the other, he knows the hadith of the Messenger (salallahu 'alayhi wa sallam) stating that once the call to commence (iqama) has been made, only the fard prayer should be performed.
The Messenger of Allah (salallahu alayhi wa sallam) said, "Once the call to commence (iqama) is made for the prayer, there is no prayer except the fard prayer (maktuba)." (Sahih Muslim 1:247) This worshipper (musalli) is unsure of what to do in this situation. Should he hurry and perform the sunnah prayer, then catch up with the imam for the fard prayer, or should he abandon the sunnah prayer altogether and join in the congregation? There is a difference of opinion among the scholars on this issue.
The Various Opinions
One opinion is that is it necessary for this person to immediately join the congregation for the fard prayer, and that it is no longer permissible for him to perform the sunnah prayer during the congregation fard prayer, just as is the ruling for other prayers.
Imam Abu Hanifa (rahmatullahi alaih) and Imam Malik (rahmatullahi alaih) are of the opinion that the person should attempt to perfom his sunnah prayer, as long as he thinks he can complete it quickly and join the fard prayer before it ends, i.e. even if he catches only the last sitting. This means that he must be confident of not missing the congregation completely, otherwise he should leave performing the sunnah and join the congregation; because, technically speaking, the congregational fard prayer is more important.
One point to remember, however, is that once the congregational fard prayer begins, the sunnah prayer should not be performed where the main congregation is in progress. It should be performed outside the main prayer-hall (masjid) area.
Another view of some Hanafi scholars is that a person should only attempt to perform the sunnah prayer if he feels confident of aquiring at least one rak'ah behind the imam. This means that he must be certain of catching up with the imam before he stands up from the bowing (ruku') of the second rak'ah of the fard.
This difference of opinion is only concerning the two-rak'ats sunnah of Fajr, and there is no controversy regarding the sunnah in other prayers. All the scholars are unanimous that once the congregation for those prayers commences, no other sunnah prayer is permissible, because although all the sunnah prayers are important, they are not as emphasized as the sunnah of Fajr. Also, if a person happen to miss the sunnah prayer of Zuhr for instance, he can make it up after the fard, since it is not a prohibited time for it.
Importance Of The Sunnah Prayer Of Fajr
1) 'A'isha (radiallahu anha) said, "The Messenger of Allah (salallahu alayhi wa sallam) was not as regular in any supererogatory (nafl) prayer as he was in the two rak'ats before Fajr." (Sahih Muslim 1:251)
2) 'A'isha (radiallahu anha) said, "I did not observe the Messenger of Allah (salallahu alayhi wa sallam) hasten towards any supererogatory (nafl) prayer as fast as he would to perform the two rak'ats before Fajr." (Sahih Muslim 1:251)
3) 'A'isha (radiallahu anha) reports that the Messenger of Allah (salallahu alayhi wa sallam) said, "The two (sunnah) rak'ats of Fajr are more superior than the world and everything within it." (Sahih Muslims 1:251)
4) 'A'isha (radiallahu anha) reports that the Messenger of Allah (salallahu alayhi wa sallam) said regarding the two (sunnah) rak'ats at the break of dawn, "They are more beloved to me than the enitre world." (Sahih Muslim 1:251)
5) Abu Hurayra (radiallahu anh) narrates that the Messenger of Allah (salallahu alayhi wa sallam) said, "Do not abandon the sunnah rak'ats of Fajr, even if horses trample over you." (Sunan Abu Dawud 1:186, Athar al-Sunan 1:224)
All the above hadiths explain the significance of and emphasis placed on the sunnah prayer of Fajr. Since the sunnah rak'ats of other prayers are not as greatly emphasized as the sunnah of Fajr, they are treated differently.
The Companions (Sahabah - radiallahu anhum) And Followers (Tabi'een - rahmatullahi alaihim) On This Issue
There are also many other rigorously authenticated hadiths which confirm that the Companions of the Messenger (salallahu 'alayhi wa sallam) would attempt to complete their sunnah prayer prior to joining the congregational fard prayer of Fajr if it had already commenced.
1) Imam Tahawi reports from Nafi': "I wakened Ibn 'Umar (radiallahu anhuma) for the Fajr prayer, while the prayer had already commenced. He arose and performed the two rak'ats (sunnah) first." (Sharh Ma'ani al-Athar 1:375)
2) Abu Ishaq says, "'Abdullah ibn Abu Musa related to me from his father regarding the time Sa'id ibn al-'As called them. He had called Abu Musa, Hadhayfa, and 'Abullah ibn Mas'ud (radiallahu anhum) before the Fajr prayer. When they departed from him, the congregation had already begun, so 'Abdullah ibn Mas'ud (radiallahu anh) positioned himself behind a pillar in the masjid and perfomed two rak'ats sunnah first, then joined the congregation." (Sharh Ma'ani al-Athar 1:374)
3) Abu 'Uthman al-Ansari reports: "'Abdullah ibn 'Abbas (radiallahu anh) arrived while the imam was leading the Fajr prayer. Since Ibn 'Abbas (radiallahu anh) had not yer performed the two rak'ats (sunnah), he performed them behind the imam (i.e. seperately), then joined in the congregation." (Sharh Ma'ani al-Athar 1:375)
4) Imam Tahawi has transmitted a report about Abu'l-Darda (radiallahu anh): "He would enter the masjid while everybody would be in rows performing the Fajr prayer. He would first perform his two rak'ats in a corner of the masjid, then join everyone in the (fard) prayer." (Sharh Ma'ani al-Athar 1:375)
5) Abu 'Uthman al-Nahdi says, "We would arrive at (times to the masjid where) 'Umar ibn al-Khattab (radiallahu anh) (was the imam), not having performed the two rak'ats (sunna) of Fajr. 'umar (radiallahu anh) would have already started the prayer, so we would perform our two rak'ats at the rear of the masjid, then join in the congregation." (Sharh Ma'ani al-Athar 1:376)
6) 'Abdullah ibn Abi Musa (radiallahu anh) narrates: "'Abdullah ibn Mas'ud (radiallahu anh) arrived while the imam was leading the Fajr prayer. He performed the two rak'ats (sunnah) behind a pillar, as he had not yet performed them." (Musannaf 'Abd al-Razzaq 1:444)
7) Harith ibn Mudrib narrated: "'Abdullah ibn Mas'ud and Abu Musa (radiallahu anhuma) left Sa'id ibn al-'As (after visiting him). The congregation (for Fajr) had just begun, so 'Abdullah ibn Mas'ud (radiallahu anh) performed two rak'ats (sunna), then joined in the row (immediately)." (Musannaf Ibn Abi Shayba 2:251)
8) Abu'l-Darda (radiallahu anh) would say regarding the sunnah of Fajr, "Yes, by Allah! If I ever enter (the masjid) and find everyone in prayer, I proceed to a pillar of the masjid and perform two rak'ats quickly; then I join the congregation and perform my Fajr with them." (Musannaf 'Abd al-Razzaq 1:443)
9) Abu'l-Darda (radiallahu anh), according to another report, states: "I (sometimes) approach the people while they are standing in rows performing Fajr. I perform two rak'ats (sunnah) then I join them." (Musannaf Ibn Abi Shayba 2:251)
10) It is reported Ibn 'Umar (radiallahu anhuma): "He would sometimes join in the congregation (immediately) and at other times he would first perform his two rak'ats at one side of the masjid." (Musannaf Ibn Abi Shayba 2:251)
11) Sha'bi narrates regarding Masruq: "He entered the masjid to find people engaged in the Fajr prayer. Since he had not yet performed the two rak'ats (sunnah), he performed them at one side, then joined the congregation in prayer." (Musannaf Ibn Abi Shayba 2:251, Musannaf 'Abd al-Razzaq 2:444)
12) It is reported that Hasan al-Basri had instructed: "When you enter the masjid and find the imam in prayer and you have not yer performed the two rak'ats of Fajr, perform them (first); then join the imam (in the fard prayer)." (Musannaf 'Abd al-Razzaq 2:245, Sharh Ma'ani al-Athar 1:376)
These are just some of the many hadiths which highlight the practise of the Companions (radiallahu anhum) and the Followers (rahmatullahi alaihim). A great jurist (faqih) like 'Abdullah ibn Mas'ud (radiallahu anh), as well as many other prominent Companions, such as Abu'l-Darda (radiallahu anh) and Ibn 'Umar (radiallahu anhuma), would first perform the two-rak'ats sunnah of Fajr and then proceed to join the main congregation. Hasan al-Basri (rahmatullahi alaih), a prominent Follower (tabi'ee) who requires no introduction, orders in clear words that the sunnah prayer be performed before joining the congregation.
Other Reasons For The Hanafi Opinion
1) The emphasis regarding the sunnah of Fajr is far greater than that of any other sunnah prayer. It has been ordered that the sunnah of Fajr be performed even if there is a danger of horses trampling over the person. Due to this emphasis, there should remain no doubt as to why the Hanafi's excluded the sunnah prayer of Fajr from the command of the hadith that informs us of only fard prayer being permissible once the congregation begins.
2) It is sunnah to make a lengthy recitation of the Qur'an during the fard of Fajr. Hence, it is possible that one could quickly perform his two rak'ats sunnah first and then join in with the imam during the first rak'ah, the second rak'ah, or just before the ima makes the salam. This is normally difficult in other prayers where a relatively shorter recitation is made and the number of rak'ats recommended before them is four.
3) In the above hadith, the command regarding the inpermissibility of any non-fard prayer at the time of congregation cannot be taken as a general command encompassing all prayers. If it was an absolutely general command, then it would also be prohibited for someone to perform the sunnah prayer in his house once he was aware that the congregation had commenced in the masjid. However, many scholars have permitted that the sunnah prayer be performed at home, even though the congregation may have already begun in the masjid. Consequently, this leaves no room to critisize the Hanafi school for excluding the sunnah of Fajr from the prohibition. Many other scholars have also not taken the command to be an absolutely general one.
4) The word "maktuba" has been used in the hadith to describe the fard prayer. The general meaning of this word includes the missed (qada') prayers also, which indicates that it would be permissible to perform the missed prayers even after the congregation has begun. However, some scholars do not allow this. From this, it is understood that the hadith is not taken literally, just as it command is not taken in a general sense.
After mentioning these points, it could be concluded that the Hanafi school has reconciled both types of hadiths by saying that the person should only perform the sunnah prayer first if he feels he can aquire the congregational fard prayer before it ends. Otherwise, he should enter immediately into the congregation with the imam. In this way, the person benefits by attaining the reward of the sunnah prayer of Fajr and also the reward of performing the fard salat in congregation.
One More Point To Remember
At times, some narrations are quoted which explicitly exempt the Fajr sunnah from the command of the hadith (which mentions the impermissibility of prayer once the congregational fard prayer has commenced). However, those narrations are usually weak, and have neither been used as a basis for the Hanafi position nor as evidence to prove the Hanafi opinion against other opinions.
Likewise, there are some narrations which specifically indicate that the sunnah rak'ats of Fajr are included in the prohibition of the hadith. The narrations mention details of a Companion confirming with the Messenger (salallahu alayhi wa sallam): "Are the sunnah rak'ats of Fajr also invalid if they are performed after the congregation has begun?" The Messenger of Allah (salallahu 'alayhi wa sallam) answers him in the affirmative saying, "Yes! They are also invalid." These narrations, being even weaker than the others, will not stand as evidence to strengthen the other group's opinion
[Fiqh al-Imam]