Commentary
We have already seen that the Prophet ﷺ would perform the two rakʿahs of Fajr, and that these two units possess certain features that set them apart from the other regular sunnah prayers, as mentioned earlier. Among those features is that, once he had finished the two rakʿahs, he would lie down on his right side, exactly as the Prophet ﷺ himself practiced. This is established in the two Ṣaḥīḥs from ʿĀʾishah (may Allah be pleased with her): whenever he had prayed the Sunnah of Fajr, he would then recline on his right flank.
In ʿĀʾishah’s second report, recorded by Muslim, she relates that the Prophet ﷺ used to pray eleven rakʿahs, giving the salutation after every two. This narration demonstrates the error of those who imagine that, when praying eleven rakʿahs, one should perform them as four, then four, then three—an assumption based on her statement: “The Prophet never exceeded, in Ramadan or outside it, eleven rakʿahs: he would pray four—do not ask about their beauty and length—then four—do not ask about their beauty and length—then three.” Some people concluded from this that he would pray four rakʿahs all together, then another four all together, and finally three.
That is a misunderstanding, the result of taking the ḥadīth at its most literal wording. Rather, it must be understood that he prayed four as two rakʿahs followed by two rakʿahs, then rested; after that, another four as two rakʿahs followed by two rakʿahs, then rested; and finally three. It has to be interpreted in this manner because there is only one narrator here—ʿĀʾishah—and the action described is a single practice. Therefore, her various reports must be reconciled so that the Sunnah remains consistent. One cannot argue that he did it one way at one time and another way at another, for the phrase “he used to” indicates continual, habitual practice.