Answered by Shaykh Faraz Rabbani
“What is the ruling of lying on one’s side before the fajr prayer?”
Abu Hurayra (Allah be pleased with him) relates: The Messenger of Allah (Allah bless him and give him peace) said, “When one of you performs the two cycles of the fajr prayer then let him lie on his side.” (Reported by Tirmidhi who declared it a well authenticated hadith)
A’isha (Allah be pleased with her) relates that, “The Messenger of Allah (Allah bless him and give him peace) used to lie on his right side after praying two cycles of the fajr prayer.” (Reported by Bukhari and Muslim). The scholars clarify that the fajr prayer mentioned in both hadiths refers to the sunna offered before the obligatory prayer.
However, lying on the side between the sunna and obligatory morning prayers is not legally recommended according to both the Malikis and Hanafis. Imam Ahmad Dardir said in his al-Sharh al-Kabir, “Lying on ones side between the sunna and obligatory fajr prayer is disliked if done if intending a sunna, though it is not disliked if done for rest.” [1:317]
Ibn Abidin said in his Radd al-Muhtar
“The Shafi`is explicitly state that it is sunna to separate between the sunna prayer of fajr and the obligatory prayer by lying on ones side based on this [quoted] and other hadiths. The position of our [Hanafi] scholars is opposed to this … Rather I saw in the Muwatta’ of Imam Muhammad [ibn al-Hasan al-Shayban, the student of Imam Abu Hanifa] (May Allah have mercy on him)
Malik related to us on the authority of Nafi’ from ‘Abdullah bin `Umar that he saw a man pray the two units of the sunna prayer of fajr and then lie on his side so Ibn ‘Umar asked, “What’s the matter with him?” Nafi` said, “I said to him [ibn ‘Umar], ‘He is separating between his prayers].” Ibn `Umar replied, “And which separation is better than the salam?” Imam Muhammad noted : I agree with the statement of Ibn `Umar and it is the opinion of Abu Hanifa (May Allah have mercy on him).
It has been related from Ibn `Umar (Allah be pleased with him & his father) that it is an innovation… Ibn Mas`ud is also reported to have dismissed it being from the sunna.”
Ibn Abidin then concluded that,
“The upshot is that the Prophet’s (Allah bless him and give him peace) lying on his side was only in his home for the sake of rest not for legislation.”
Therefore, it is not a prescribed sunna. Given this, performing it believing it to be a sunna would blameworthy. If one did it, at home (not at the mosque), to follow the habitual practice of the Prophet (Allah bless him & give him peace) while believing that it is not an established sunna, there would be nothing wrong with it; rather, one would have reward for following the practice of the Prophet.
And Allah knows best.
Sohail Hanif & Faraz Rabbani.