9 – Khulʿ must be concluded with an explicit verbal formula, for the Prophet ﷺ said: “and pronounce a single divorce.”

Scholarly disagreement
The jurists differ as to whether khulʿ counts as one of the husband’s three divorces, or whether it is a dissolution (fas­kh) that does not reduce the number of remaining divorces.

• Imām al-Shāfiʿī held that it is a dissolution, not a divorce; this is also one report from Aḥmad, though it is not the famous view of his school.
• This position was chosen by Ibn Taymiyyah, Ibn al-Qayyim, and many later verifiers. Among more recent Ḥanbalīs it was adopted by Shaykh Muḥammad b. Ibrāhīm and Shaykh ʿAbd al-Raḥmān al-Saʿdī. From the early generations it was the view of Ibn ʿAbbās, Ṭāwūs, ʿIkrima, Isḥāq, and Abū Thawr.

• The other three imams—Abū Ḥanīfa, Mālik, and Aḥmad—together with al-Thawrī and al-Awzāʿī, regarded it as a single irrevocable divorce.
• Among the predecessors this was likewise reported from Saʿīd b. al-Musayyib, ʿAṭāʾ, al-Ḥasan, Mujāhid, Abū Salama b. ʿAbd al-Raḥmān, al-Nakhaʿī, al-Shaʿbī, al-Zuhrī, and Makḥūl, and it is narrated from ʿUthmān, ʿAlī, and Ibn Masʿūd.

Those who consider it a dissolution adduce the verse, “Divorce may be pronounced twice” (al-Baqarah 2:229); these are the two pronouncements after which the husband retains the right of return. Concerning the third pronouncement Allah says: “If he divorces her, she is thereafter not lawful for him until she marries another husband” (al-Baqarah 2:230). Between mention of the first two pronouncements and the third comes His statement: “But if you fear that they will not maintain the limits of Allah, then there is no blame on either of them if she ransoms herself” (al-Baqarah 2:229)—and this is khulʿ. Had khulʿ been a divorce, it would necessarily have been the third pronouncement; since it is placed between the first two and the third and is not counted among them, it is understood to be a mere dissolution.

Shaykh al-Islām, endorsing the first view, said: “The apparent position of Aḥmad and his companions is that it is an irrevocable separation, an annulment of the marriage, and not one of the three divorces. I have not known anyone from…"