It is permissible to pray voluntary prayers at night at any time from after the ῾Ishā᾽ prayer until dawn (Fajr), whether it is after Witr or before it. The allowance for voluntary prayers after Witr has been reported both in word and deed by the Prophet, peace be upon him:
As for his deed, Muslim narrated through his chain from Abū Salamah, who said: I asked ῾Aā᾽ishah, may Allāh be pleased with her, about the prayer of the Messenger of Allāh, peace be upon him, and she said: “He used to pray thirteen rak῾ahs. He would pray eight rak῾ahs, then pray Witr, then pray two rak῾ahs sitting down. When he wanted to bow, he would stand and bow, and then pray two rak῾ahs between the adhān and ᾽iqamāh of the Fajr prayer.”
As for his words, Ibn Ḥibbān and others narrated from Thawbān, may Allāh be pleased with him, the servant of the Messenger of Allāh, peace be upon him, who said: We were with the Messenger of Allāh, peace be upon him, on a journey, and he said: “This journey is a strain and burden, so when one of you has prayed Witr, let him pray two rak῾ahs, for if he wakes up, well and good, and if not, they will be recorded for him.”
The majority of scholars from the Ḥanafī, Shāfi῾ī, and Ḥanbalī schools, as well as Ibn Ḥazm al-Ẓāhirī, have supported the permissibility of praying voluntary prayers after Witr. Some even consider it recommended, based on the aforementioned ḥadīth, especially for travelers.
As for the Prophet’s, peace be upon him, statement in the ḥadīth reported by al-Bukhārī and Muslim through their chains from ῾Abdullāh ibn ῾Umar, may Allāh be pleased with them, where the Prophet, peace be upon him, said: “Make the last of your prayers at night Witr,” this is taken as a recommendation to encourage people to end their night prayers with Witr. For those who cannot guarantee that they will wake up later, it is better to pray Witr earlier, and if Allāh allows them to wake up later, they can pray additional prayers. If they do not wake up, they have already prayed Witr for that night.
Fatwā issued by Dr. Khālid Naṣr