Among the matters he lists as nullifying the fast is his statement: “Masturbation—i.e., the emission of semen—whether it results from a man kissing his wife, embracing her, or using the hand, breaks the fast and obliges one to make up the day.”
I say: There is no proof that this act invalidates the fast, and likening it to full intercourse is not evident. For that reason al-Ṣanʿānī said:
“The stronger view is that neither making up the day nor expiation are required except of one who has actually had intercourse; extending the same ruling to anyone else is far-fetched.”
Al-Shawkānī inclined to this opinion as well, and it is the position of Ibn Ḥazm; see al-Muḥallā 6/175–177 and 205.
What further shows that drawing an analogy between masturbation and intercourse is defective is that some who held it to invalidate the fast did not impose expiation for it. They argued, “Intercourse is more severe, and the default is that no expiation is due.” See al-Muhadhdhab with al-Nawawī’s commentary 6/368.
We therefore likewise maintain: the default is that the fast is not broken, and intercourse is weightier than masturbation.