Shaykh al-Islām—may Allah sanctify his soul—said:

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Allah has mentioned night prayer in several verses, sometimes praising it and sometimes commanding it—initially as an obligation, which He then replaced with a recommendation. This applies if night prayer does not include the ‘Ishā’ prayer, but rather means praying after sleep. For Sa‘īd ibn al-Musayyib and others said, “Whoever prays ‘Ishā’ in congregation has obtained his share of prayer on Laylat al-Qadr.” He thus counted this as night prayer.

It is reported from ‘Ubaydah al-Salmānī that night prayer remains obligatory and that its obligation has not been abrogated, even if one prays only for as long as it takes to milk a sheep. If this is intended to include the witr prayer, then it is the view of many scholars.

The evidence for this is the hadith of Ibn Mas‘ūd: when the Prophet said, “Pray witr, O people of the Quran,” a Bedouin asked, “What is the Messenger of Allah saying?” He replied, “This is not addressed to you or your companions.”

Thus, he addressed the people of the Quran with a command concerning night prayer that he did not address to others.