“Yet there are other ḥadīths which decisively state that sleep does not invalidate ablution unless the sleeper is lying down. These reports strengthen one another—as I have shown in my commentary on al-Muntaqā—and therefore qualify the narrations that speak, in absolute terms, of sleep breaking ablution: only the sleep of one who is reclining nullifies it.”
If you consult that commentary you will find that he cites three ḥadīths:
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The first is from Ibn ʿAbbās: “No ablution is required of one who falls asleep while prostrating….” Although he himself records that a large number of leading scholars declared it weak, and that al-Bayhaqī said: “All the ḥadīth masters rejected it from Abū Khālid al-Dalānī,” he nevertheless tried to bolster it with al-Dhahabī’s remark about al-Dalānī in al-Maʿnī: “He is well-known, his ḥadīth are ḥasan.”
Anyone familiar with this discipline realizes that, even if such praise were conceded, it does nothing to strengthen the report; the early specialists in ḥadīth unanimously rejected it, as noted above. All the more so when Ibn Ḥajar said of al-Dalānī, “Reliable, but he makes many mistakes and practiced tadlīs.” Al-Dhahabī himself, moreover, listed this very ḥadīth in al-Mīzān among the narrations for which al-Dalānī was censured. And the chain contains three additional defects that I have detailed in my book Ḍaʿīf Abī Dāwūd, no. 25—one of which, that it is mawqūf, al-Shawkānī himself mentioned, yet he simply passed over it!
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The second report, with similar wording, is traced back to the Prophet through Ibn ʿAmr. Al-Shawkānī notes: “Its chain contains Mahdī ibn Hilāl, who is accused of fabricating ḥadīth; ʿUmar ibn Hārūn al-Balkhī, who has been abandoned; and Muqātil ibn Sulaymān, who is likewise suspected.”