is the highest number reported. Accordingly, if a person performs ten rak'ahs with five taslims, the ninth and tenth rak'ahs would constitute unrestricted voluntary prayer, not part of the Duha prayer.

The correct view is that there is no upper limit to it, for Aisha, may Allah be pleased with her, said: “The Prophet, peace and blessings be upon him, would pray four rak'ahs of Duha, and would add as much as Allah willed.” Recorded by Muslim (1). She did not specify any limit. Thus, even if one were to pray, for example, forty rak'ahs from the time the sun has risen to the height of a spear until shortly before its zenith, all of this would fall under the Duha prayer.

The hadith of Umm Hani may be answered in two ways:

The first answer is that many scholars held that this prayer was not the Duha prayer, but rather the prayer of conquest. They recommended that, when a commander conquers a town, he pray eight rak'ahs there in gratitude to Allah, the Exalted, for granting him its conquest. For it is among Allah’s blessings upon him that He has enabled him to conquer the town, and such a blessing calls for humble devotion, humility before Allah, and diligence in obeying Him.

For this reason, we know of no one who conquered a city greater than Mecca, nor of any conqueror greater than Muhammad, peace and blessings be upon him. Yet when he entered Mecca after conquering it, he had bowed his head, peace and blessings be upon him, while reciting the words of Allah, the Exalted: “Indeed, We have granted you a clear victory.” [al-Fath] He recited it with a repeated modulation (2)—that is, as though he repeated a letter twice. This was part of the completeness of his humility, peace and blessings be upon him, for among the greatest blessings is that Allah should grant you victory over the land of your enemies. Allah, the Exalted, says: “Fight them; He will punish them