In a prayer schedule there is the time for Fajr and Shuruq. Shuruq time indicates the end of the Fajr prayer. Since we cannot pray immediately after Shuruq, when can we perform the Duha prayer? How many minutes after the Shuruq time in a prayer schedule can one pray Duha?
To begin with, the majority of the classical scholars are of the opinion that the post-sunrise prayer (ishraq) is the same as the mid-morning prayer (duha). This is the very reason why the major classical books of Hanafi Fiqh do not mention the two prayers separately. (See: Abu Bakr al-Jassas, Ahkam al-Qur’an, 3/559)
However, the common perception (especially amongst the Hanafis of the Indian Subcontinent) is that Salat al-Ishraq and Salat al-Duha are two separate prayers. The recommended time for offering Ishraq prayer is immediately after sunrise, whilst the Duha prayer (which they call the Chasht prayer) is offered later on. (See: Heavenly Ornaments, P: 143)
The reasoning behind this, in my humble view, is that the Messenger of Allah (Allah bless him & give him peace) has encouraged offering this prayer directly after sunrise. Sayyiduna Anas ibn Malik (Allah be pleased with him) narrates that the Messenger of Allah (Allah bless him & give him peace) said: “Whosoever offers his morning (fajr) prayer in congregation, then remains seated making the dhikr of Allah until the sun rises, and thereafter offers two rak’ats, they will receive the reward of performing a Hajj and Umrah.” (Sunan Tirmidhi, no: 586)
This Hadith implies that one should offer this optional prayer directly after sunrise by remaining seated on the very place one offered the Fajr prayer and by engaging in d’ua and other forms of dhikr. Thereafter, when the sun has risen properly, one should offer the Ishraq or Duha prayer.
On the other hand, there are many Hadiths which recommend offering this prayer later on. The Fuqaha also mention the recommendation of offering it at mid-morning (halfway between sunrise and zawal (time of the sun’s zenith). Thus, the Hanafi Ulama of the Subcontinent have considered both these to be two separate forms of prayer, and this is what we find in their books.
However, the major classical Hanafi books, such as Radd al-Muhtar, al-Fatawa al-Hindiyya and others, do not mention Salat al-Ishraq and Salat al-Duha to be two separate prayers; rather, they only have place in their respective works for one prayer which they term as the Duha prayer.
The author of Umdat al-Fiqh mentions a very good point in this regard. He states that there are two separate prayers for Duha. The first prayer is known as the Ishraq prayer, the time of which begins after the sun rises up until it is above the horizon by the length of a spear and it ends at mid-morning. This prayer is also known as the minor Duha prayer. The second prayer is known as the Duha prayer, and its time also begins when the sun has risen to a spear’s length above the horizon, and it ends at zenith, although the preferred time to offer this prayer is at mid-morning (i.e. midway between sunrise and zenith). This prayer is also known as the major Duha prayer. According to the majority of Hadith scholars and Fuqaha, if one was to offer one’s prayer directly after the sun has risen to a spear’s length above the horizon, it would be considered both the Ishraq and the Duha prayer. However, if one was to offer it later at around midday, then it will only be considered as the Duha prayer. (See: Sayyed Zawwar Husayn, Umdat al-Fiqh (Urdu), 2/302)
In light of the above from Umdat al-Fiqh and also in light of the understanding of the classical Hanafi fuqaha, it can be said that the Ishraq prayer and the Duha prayer are both one. However, by performing this prayer early on when the sun has risen to a spear’s length, one will gain extra rewards, and by offering it later on, one will still be considered to have offered the Duha prayer. For this very reason, we see many saintly people making an effort to offer the Duha (or Ishraq) prayer immediately after the sun has risen to a spear’s length.
We see the various classical Hanafi books discussing the Duha prayer without stipulating two separate prayers. For example, it is stated in al-Fatawa al-Hindiyya:
“And from the recommended prayers is the Duha prayer. Its minimum is two rak’ats and its maximum is twelve rak’ats. Its time is from after sunrise to when the sun is at its zenith (zawal).” (al-Fatawa al-Hindiyya, 1/112)
There are many Hadiths which encourage us to offer the Duha prayer:
Sayyiduna Abu Hurayra (Allah have mercy on him) narrates that my beloved companion (the Messenger of Allah, Allah bless him & give him peace) advised me three things: To fast three days of every month, to perform the two rak’ats of Duha, and that I perform my Witr before retiring to bed.” (Sahih al-Bukhari: no: 1981)
Sayyida A’isha (Allah be pleased with her) narrates that the Messenger of Allah (Allah bless him & give him peace) would offer four rak’ats at the time of Duha, and increase on it whatever Allah wished.” (Sahih Muslim, no: 719)
It is mentioned by Imam al-Haskafi (and confirmed by Imam Ibn Abidin) that while its minimum is two rakats, the minimum optimal amount is four rakats, as this was the general practice of the Messenger of Allah (Allah bless him & give him peace). (See: Radd al-Muhtar, 2/22-23)
As for your specific question (how many minutes after sunrise can one perform the Duha prayer) is concerned, it should have been answered in the above explanation, in that one may perform it after the sun rises up until it is above the horizon by the length of a spear, meaning when the sun becomes bright and it is difficult to look directly at the sun with the naked eye. This can take approximately fifteen to twenty minutes after sunrise.
And Allah knows best
[Mufti] Muhammad ibn Adam
Leicester , UK