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As for someone who performed a prayer before remembering the forgotten prayers, he need repeat it only within its prescribed time, as a recommended observance of their proper sequence. If insufficient time remains to repeat it, he need not repeat it after the time has expired. If, however, sufficient time remained but he did not repeat it, one view holds that he should repeat it after the time has expired. This serves to reinforce the recommendation.
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There are thus two views concerning the sequence between a small number of missed prayers and prayers whose time has arrived. The first is that observing this sequence is obligatory when one remembers, but the obligation lapses through forgetfulness, as with the prohibition on speaking during prayer. The second is that it is required only by the Sunnah, in the manner that Sunnah practices are required. As for observing the sequence between prayers whose time has arrived, I know of no disagreement that this is obligatory when one remembers, as we have explained, Allah willing.
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As for someone who remembers a large number of missed prayers, Mฤlik consistently held that he should begin with the prayer whose time has arrived before making them up. According to one view, this applies if he fears that its preferred time will expire; this is the apparent meaning of Ibn Habฤซbโs statement in al-Wฤdiha. According to another, it applies so long as the sun has not turned yellow, in the case of the noon and afternoon prayers; this is Ibn al-Qฤsimโs view in Yahyฤ ibn Umarโs Mukhtasar. According to another, it applies so long as the sun has not set; this is Ibn al-Qฤsimโs view in Sahnลซnโs transmission recorded in al-Utbiyya.
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The basis for Mฤlikโs distinction between a large and a small number of missed prayers is that the apparent meaning of the hadith, taken in its full generality, requires beginning with the missed prayers, whether few or many, before the prayer whose time it is, even if its time expires. For the Prophet said:
โLet him pray it when he remembers it.โ
This refers to prayer, a term of general scope. Scholarly consensus excludes a large number of missed prayers from this general ruling, while the hadith remains applicable to a small number. There is disagreement over the threshold: some say four, others five, and others six. Six is the correct view, since the hadithโs general scope can only be restricted by what is agreed to constitute a large number, namely six prayers. Allah alone grants success.