In the name of Allah, the Most Gracious, the Most Merciful. All praise belongs to Allah, Lord of the Worlds. Prayers and salutations be upon the Master of the Messengers ﷺ, and upon his family and Companions. There is no power nor strength except through Allah, the Mighty, the Wise.
If someone has missed ṣalāh and is unable to determine or be certain of the exact number he has missed, then he must perform enough ṣalāh to be confident that no outstanding ṣalāhremains due from him. This is because the default principle is that one’s liability remains established, and nothing removes that liability except what is known with certainty.
For this reason, the fuqahāʾ say: “What is established with certainty cannot be discharged except with certainty.”
The Mālikī ʿAllāma al-Ḥaṭṭāb (may Allah have mercy on him) said: “If a person has many missed ṣalāh and cannot determine their number, he should estimate their amount and take precautions for the sake of his Dīn by praying enough to remove any doubt. But doubt without any indication is merely baseless misgiving [waswasa], so he should not continue making them up indefinitely as some elderly people and the ignorant do.”
Imām al-Ramlī (may Allah have mercy on him) said: “Whoever has missed ṣalāh but does not know their number: al-Qaffāl said he should make up what he is certain he missed. Al-Qāḍī Ḥusayn said he should make up more than what he is certain he actually performed (as a precautionary measure), and this is the sounder opinion.”
Imām Ibn Qudāma (may Allah have mercy on him) reported: “Abū Dāwūd narrated from Aḥmad regarding a man who had neglected ṣalāh—such as the ʿAṣr prayer of one day and the Ẓuhr prayer of another—and other prayers whose number he did not know. He said: ‘He should repeat them until nothing remains in his heart (i.e., until he feels assured).’ The apparent meaning of this is that he continues making them up until he is certain that his liability has been cleared. This is also the position of Imām Abū Ḥanīfa.”
Etiquette:
Shaykh Zarrūq (may Allah have mercy on him) said: “Whenever a person cannot determine exactly how much ṣalāh, zakāt, or other obligations he owes, then careful estimation [taḥarrī] is sufficient for him. He should take precautions for the sake of his religion without falling into waswasa. Acting on mere doubt without any indication—such as what many repentant people do by performing ‘a lifetime of prayers’ even though they did not actually abandon them, or perhaps only missed them occasionally—is not appropriate. I heard this from our teacher, Abū ʿAbd-Allāh Muḥammad b. Yūsuf al-Sanūsī, the leading scholar of Tlemcen in knowledge and piety, and al-Qarāfī transmitted it from us in his teaching session.”
And Allah knows best.
