Some scholars, however, held that this hadith should be acted upon. They said that a person may offer voluntary prayer while lying down, but that his reward is half the reward of one who prays seated, and thus one quarter of the reward of one who prays standing.
This is a strong view, because the hadith is in Sahih al-Bukhari, and because it encourages voluntary prayer. At times, a person may be sluggish, even though he is able to pray seated, but feels somewhat lazy and would prefer to pray lying down. So, in order to encourage him to perform this righteous voluntary deed, we say: Pray lying down, but you will receive only one quarter of the reward of one who prays standing and half the reward of one who prays seated. For this reason, the scholars permitted a person performing voluntary prayer to drink a small amount of water, in order to make voluntary worship easier for him. Voluntary acts of worship are more flexible than obligatory ones.
The Duha Prayer Is Recommended
His statement, “The Duha prayer is recommended”: the Duha prayer is an attribution of the act to its time. Or one may say that it is an attribution of the act to its cause, just as one says the Zuhr prayer, attributing it to its time, and the time is its cause.
His statement, “is recommended,” is well known: a sunnah is that which is commanded without being obligatory.
The ruling on a sunnah is that the one who performs it is rewarded, while the one who leaves it is not punished.
The evidence for this is that the Prophet, may Allah’s peace and blessings be upon him, said to the man whom he taught the five daily prayers, when the man asked, “Am I required to perform anything besides them?” He replied: “No, unless you perform voluntary prayers” (1).