Some scholars drew a distinction, saying: As for one who is accustomed to praying at night, it is not recommended for him to pray Duha; but as for one who has no regular practice of night prayer, then it is an unrestricted sunnah for him every day.
The fourth view is that it is a non-regular sunnah; that is, one performs it on some occasions and leaves it on others.
The stronger view is that it is an unrestricted sunnah to be performed consistently. It is authentically established that the Prophet, may Allah’s peace and blessings be upon him, said: “Every morning, charity is due from every joint of each one of you…” the hadith (1).
It is also authentically reported from the Prophet, may Allah’s peace and blessings be upon him, that “Allah created the son of Adam with three hundred and sixty joints” (2).
The term sulāmā refers to the bones that are separate from one another. Thus, every person owes three hundred and sixty acts of charity each day. Yet this charity is not monetary charity; rather, it includes everything that brings one nearer to Allah. The Prophet, may Allah’s peace and blessings be upon him, said: “Every declaration of Allah’s perfection is charity; every praise of Allah is charity; every declaration that none has the right to be worshipped but Allah is charity; every declaration of Allah’s greatness is charity; enjoining what is right is charity; forbidding what is wrong is charity; and two rak'ahs that one prays in the Duha time suffice for all of that” (3).
Based on this hadith, we say that it is recommended to pray these two rak'ahs consistently, because most people are unable to perform these three hundred and sixty acts of charity.