Those on whom sujuud As-Sahwu [prostration of forgetfulness] is an obligation after tasleem might sometimes forget doing it immediately after Tasleem. Some scholars of Fiqh said that if one remembers doing Sujuud As-Sahw after a long period of time of doing Salaah , he does not have to do it. This long period of time they refer to does not, however, have limits. Others stated the Sujuud As-Shawu should be done provided that he has not left the mosque, otherwise this Sujuud is not considered as an obligation on him. A third party of scholars of Fiqh said that either the long period of time [after reciting Tasleem] or getting out of the mosque renders doing Sujuud As-Sahwu as non obligatory.
The soundest of all the opinion is the one held by Ahmad and Shaafi'ee and stated by Shaykh Ibn Taymiya in "Majmuu`Al-Fataawaa" which states that one should do Sujuud As-Sahw [if they need to do so exists] whether one remembers it after along time of doing Salaah or after getting out the mosque for no Shari'a (legal) proof specifies doing Sujuud As-Sahw at a certain time or place. Another mistake done by some praying Muslims is reciting Tashahhud after doing Sujuud As-Sahw, and before reciting Tasleem! They build their practice on a weak hadeeth that runs as follows: The prophet [peace and blessings of Allaah be upon him] led his companions in Salaah and forgot to do a part of it; consequently, he [peace and blessings of Allaah be upon him] did Sujuud As-Sahw ,recited Tashahhud and finally recited Tasleem; This hadeth was narrated by: Abuu Daawuud and others. This narration is an odd and weak one and in my opinion, this hadeeth is not authentic. I believe that even if the hadeeth's chain of narrations appears to be authentic, the narration regarding reciting Tashahhud before Tasleem is an odd one for Al-Ashath Ibn Abdil Malik was the only one to mention it . The authentic narration of the hadeeth does state reciting Tashahhud before saying Tasleem; `Imran Ibn Husain said that once the prophet (peace and blessing of Allaah be upon him) perform three rakaat for Asr Salaat, then recited tasleem . He was told that he performed only three Rakaat . He then performed one Rakaat then recited tasleem followed by two Sujuuds and finally recited another tasleem. [ Muslim ]
When Ibn Seereen was asked about Tashahhud after doing Sujuud As-Sahw; he said: "I have never heard something [i.e authentic Hadeeth] about Tashahhud". The false addition to the dhikr recited in Sujuud As-Sahw: Some Muslims say in Sujuud As-Sahwu `Subhaana Man Laa Yashuu Walaa Yanaam [Glory be He who never forget nor sleeps] Which is a false addition that is not affirmed to be of sunnah.
Al-Qushairee said : "It was not confirmed that the prophet (peace and blessings of Allaah be upon him ) recited a certain dhikr in Sujuud As-Sahw save those ordinary Athkaar which he used to recite in any other Sujuud . As for the statement that say’s :"Subhaana Man Laa Yashuu Walaa Yanaam": it is not of the prophet's (peace and blessings of Allaah be upon him) Sunnah nor is it of his Companions practice , nor is supported by an established authentic proof : it is indeed of the suufis falsehood that should be strictly abandoned . Religion should be taken from the authentic, pure, Sunnah-books . Documenting such a false statement in a complication as part of religion is indeed grave falsehood".
This article was culled from the publications of Deen Communication Limited