A martyr is one who is killed in a battlefield fighting the enemies of Islam. All the hadith on this subject are quite explicit that no funeral prayer may be offered for a martyr.
Bukhari has narrated from Jabir that the Prophet, peace be upon him, ordered that the martyrs of the battle of Uhud be buried while they were still bleeding. He neither washed them nor offered a funeral prayer for them.
Ahmad, Ahu Daw ‘ud and Tirmizhi reported that Anas said: “The martyrs of Uhud were not washed. They were buried with their wounds unwashed, and no funeral prayer was offered for them.”
There are, however, some hadith that are equally explicit and state that a funeral prayer should be offered for martyrs. Bukhari reported from ‘Uqbah ibn ‘Amir that one day the Prophet, peace be upon him, went out and offered a funeral prayer for the martyrs of Uhud, eight years after their death, as if he were bidding farewell to both the living and the dead.
Abu Malik Al-Ghafari reported: “The bodies of the martyrs of Uhud were brought in batches of nine and placed with the body of Hamzah, who served as the tenth. Then the Prophet, peace be upon him, offered a funeral prayer for them. After that the nine bodies were removed leaving Hamzah undisturbed. Then a batch of another nine martyrs was brought and placed beside Hamzah. The Prophet, peace be upon him, offered a funeral prayer for them as well. This way the Prophet offered funeral prayer for all of them. This hadith has been narrated by Al-Baihaqi, who says: “This is the most sound hadith on this subject. It is, however, a mursal hadith. (Mursal: A hadith that rests on a chain of authorities going no further back than the second generation after the Prophet (peace be upon him))
The difference in the narrations in these various hadith has led jurists to differ on this matter. Some take all of them together, while others prefer some narrations over others. Ibn Hazm holds that either – offering or not offering (funeral prayer for the martyrs) – is permissible. It is alright whether or not a funeral prayer is offered for the martyrs. In one of his statements Ahmad has also expressed a similar view. Ibn al-Qayyim approves of this view and says: “The correct position in this regard is that one is given a choice whether or not to offer a funeral prayer (for a martyr), because there are reports in favour of both positions.” This is the opinion also of Ahmad, and he is the proper person to describe the principles of his school. He says: “What is apparent from this is that no funeral prayer was offered for the martyrs of Uhud before burying them. There were seventy people who fell martyrs in that battle, and any funeral prayer for them could not have taken place in secret.”
The hadith reported by Jabir ibn ‘Abd Allah that the Prophet, peace be upon him, did not offer funeral prayer for these martyrs is sound and very explicit. Jabir’ s father was among those who were killed that day, and he knew what few besides him knew.
Abu Hanifah, Al-Thawri, Al-Hasan, and Ibn Al-Musayiyaib, however, are inclined to the reports stating that the Prophet, peace be upon him, did offer funeral prayer for the martyrs. They hold that a funeral prayer must be offered for martyrs. However, Malik, Ash-Shafi’i, Ishaq, and, according to one report, Ahmad, prefer the reports that say no funeral prayer is to be offered for martyrs. Ash-Shafi’i in his Kitab al-Umm writes: “All reports received concerning this subject are sound and show that the Prophet, peace be upon him, did not offer funeral prayer for the martyrs of Uhud. Those who report that he offered funeral prayer for them and said seventy takbirs for Hamzah are not correct. Those who turn away from these sound hadith should be ashamed of themselves. The hadith reported by ‘Uqbah ibn ‘Amir also states that the Prophet, peace be upon him, did so eight years after their death, as if he were bidding them farewell. This does not constitute abrogation of an established practice. (See Al-Umm. by Ash-Shafi’i)