By Mln. Saad Hussain (Takmīl Graduate, 2019)
The permissibility of a woman leading men in prayer is a question that has recently surfaced in the American Muslim community. Current modernist trends in our milieu have prompted this discussion point. One of the most telling events that emanated out of this was when Amina Wadud lead a mixed-gender Friday prayer a few years back. This event sparked a discussion amongst Muslims. In this paper, I will first address what the scholars of fiqh said regarding this issue. And then, I will discuss textual evidence that is central to it: Umm Waraqah’s ḥadīth.
However, there are four scholars who said that she can lead men. They are Abū Thawr, Muzanī, Ṭabarī, and Ibn ʿArabī. Additionally, some Ḥanbalīs said that a woman can lead men specifically in the tarāwīḥ prayers. They based their opinion on the ḥadīth of Umm Waraqah.
Umm Waraqah was one of the Prophet Muḥammad’s female companions. She was a proficient reciter of the Qurʾān and used to lead her household in prayers. This ḥadīth is narrated in a few ḥadīth collections. I was able to find nine chains of transmission (ar. asānīd) from Musnad Aḥmad, Sunan Abī Dāwūd, Musnad Ibn Jārūd, Ṣaḥīḥ Ibn Khuzaymah, Sunan al-Dāraquṭnī, Sunan al-Bayhaqī, and Mustadrak al-Ḥākim. The strength of these chains must be analyzed.
All of them rely on Walīd b. Muslim. He narrated the ḥadīth from both Laylā bint Mālik, who is his grandmother, and also from ʿAbd al-Raḥmān b. Khallād. There are some chains in which he narrated from both. And in other chains, he only narrated via ʿAbd al-Raḥmān, and in others he only narrated from Laylā. I will limit the discussion to these three narrators because all the chains pivot on them.
The first narrator is Walīd b. Muslim. He is classified as an honest narrator who sometimes makes mistakes (ar. ṣadūq yahimu). This may seem concerning, but Imām Dhahabī says that Imām Muslim narrates Walīd’s transmissions as evidence (ar. fī mawdiʿ al-iḥtijāj). From this, we know that Walīd is reliable.
The next narrator is Laylā bint Mālik. Ibn Ḥajar said that she is not known (ar. lā tuʿraf). Considering his grading, we cannot determine her reliability.
The last narrator is ʿAbd al-Raḥmān b. Khallād. Ibn Ḥajar declared him to be majhūl al-ḥāl. Again, the grading means that we cannot determine the narrator’s reliability. And because of the presence of Laylā bint Mālik and ʿAbd al-Raḥmān b. Khallād, this ḥadīth is weak.
Still, some people claim that it is authentic. Jonathan Brown, in Misquoting Muhammad, claimed this. He suffices with the opinion of three scholars: Ibn Khuzaymah, Ḥākim, and Albānī. Ibn Khuzaymah and Ḥākim claimed to only narrate sound narrations in their collections. And Albānī is known to be stringent when grading narrations. The question at hand is about blindly accepting their judgments without further reviewing the matter. Another question is if their judgements are decisive enough that we can overlook the problems in the narrations’ chains. To determine this, we must consider what the prominent figures in the field of ḥadīth said regarding these three scholars.
Regarding Ibn Khuzaymah, Ṣanʿānī says:
“…in any case, it’s necessary for someone familiar with ḥadīth sciences to look further into the soundness of the ḥadīth. These types of scholars, such as Ibn Khuzaymah, Ibn Ḥibbān, and Ḥākim are not followed blindly. How many times has Ibn Khuzaymah declared a ḥadīth to be ṣahīh that is at most ḥasan?”
He goes on to say:
“Do not consider what the author says to be a definitive statement (ḥukm kullī).”
From this we learn that Ibn Khuzaymah doesn’t maintain the most stringent conditions when grading narrations.
Ḥākim is also known to be lax. Ibn Ḥajar said:
“Hākim and Ibn Jawzī’s tasāhul mitigates their judgements. It is for this reason that one must give special attention to the narrations quoted from their works. One should not blindly follow them.”
Dhahabī echoes the same sentiments:
“Undoubtedly, there are many narrations in this book that do not meet the criteria of ṣiḥḥah. There are even many fabricated narrations in it.”
Just like Ibn Khuzaymah, Ḥākim does not have stringent conditions.
Lastly, there is Albānī. In his footnotes on Sunan Abī Dāwūd, he declares the narration to be ḥasan. Albānī is known to be strict when he grades. Thus, when he declares that a narration is ḥasan, one may presume that he is not being lax. However, Albānī is prone to mistakes. Salāḥ al-Dīn al-Idlībī argues in his book Kashf al-Maʿlūl that because Albānī made so many mistakes, one can’t unequivocally rely on his judgements. Idlībī then presents ten misunderstandings that Albānī has in the field in ḥadīth.
He mentions one misunderstanding that potentially gives us insight into why Albānī declared the ḥadīth of Umm Waraqah to be ḥasan. He says:
“Despite him being aware of Ibn Ḥibbān’s laxity, he considers a narrator reliable if the narrator is mentioned in al-Thiqāt and has at least three students.”
What’s interesting is that in al-Thiqāt, Ibn Ḥibbān mentions both Walīd and ʿAbd al-Raḥmān. Perhaps this is why Albānī declared the chain to be ḥasan.
At this point, we have established that one cannot rely on the judgements of Ibn Khuzaymah, Ḥākim, and Albānī. Ibn Khuzaymah and Ḥākim are lax when grading, so their quoting a narration does not mean it is sound. Albānī is strict, but he makes mistakes and thus his judgments are not conclusive. Putting this aside, even if a reliable scholar were to declare this ḥadīth to be sound, it wouldn’t change the fact that there are two unknown (ar. majhūl) narrators in every chain of transmission. Accordingly, the ḥadīth is weak.
Now that we have established that the ḥadīth is weak, we can address the legal aspects which pertain to this discussion. All the scholars who opine that a woman can lead ṣalāh rely on the ḥadīth of Umm Waraqah. Now, if the ḥadīth is weak, their argument is no longer valid. Nawawī, a leading authority in the field of ḥadīth, said:
“It is permissible to practice on weak narrations except for in theological issues, establishing Sacred Law, etc.”
A woman leading men in prayer is a legal matter and thus it cannot be established by relying on a weak ḥadīth.
Jonathan Brown concluded his article with the following remarks:
“It is revealingly plain that if this issue did not involve the knot of gender and power, the evidence for permitting it would carry the day without controversy.”
It seems like Dr. Brown is misconstruing the evidential basis on this issue and implying that a male bias and yearning for power clouded the judgment of those who are surely free from that. The matter is rather simple however, a minority of scholars said that a woman can lead men. And they base their argument on the ḥadīth of Umm Waraqah, which is weak. Consequently, their, and likewise Dr. Brown’s, argument is weak.
 al-Baḥr al-Rāʾiq, Ibn Nujaym al-Miṣrī, 1:372. Bidāyat al-Mujtahid, Ibn Rushd, p. 123. al-Majmūʿ, Nawawī, 2: 254-255. al-Mughnī, Ibn Qudāmah, 2:146-147.
 al-Iqnāʿ fī Masāʾil al-Ijmāʿ, Ibn al-Qaṭṭān, 1:144.
 Bidāyat al-Mujtahid, Ibn Rushd, 123. al-Majmūʿ, Nawawī, 2:254-255.
 al-Mughnī, Ibn Qudāmah, 2:146-147.
 Musnad Aḥmad, 25:225, #27283. Sunan Abī Dāwūd, 1:161, #591 & #592. al-Muntaqā li Ibn Jārūd, 1:91, #333. Ṣaḥīḥ Ibn Khuzaymah, 3:89, #1676. Sunan al-Dāraquṭnī, 2:21, #1084; 2:261, #1506. Sunan al-Bayhaqī, 1:215; 1:597; 3:186. al-Mustadrak, Ḥākim, 1:320.
 Taqrīb al-Tahdhīb, Ibn Ḥajar, 582.
 al-Mustadrak ʿalā al-Ṣaḥīḥayn, Ḥākim, 1:320.
 Taqrīb al-Tahdhīb, Ibn Ḥajar, 763.
 Ibid, 339.
 Misquoting Muhammad, Brown, 194.
 Tawḍīḥ al-Afkār, Ṣanʿāni, 1:61.
 Qawāʿid al-Taḥdīth, Ḥallāq, 249.
 Tadhkirat al-Ḥuffāẓ, Dhahabī, 3:164.
 Ṣaḥīḥ wa Daʿīf Abī Dāwūd, Albānī, 2.
 Kashf al-Maʿlūl, Idlībī, 7-9.
 al-Thiqāt, Ibn Ḥibbān: Walīd‘s biography is found at 5:492, and ʿAbd al-Raḥmān‘s at 5:98.
 Tadrīb al-Rāwī, Suyūṭī, 3:522, Dār al-Yusr.
 Misquoting Muhammad, Brown, 199.