What has been said above concerned the making of Du` a’ for one’s needs. If Du’a’ is taken in the sense of Dhikr (remembrance) and `Ibadah (worship) at his place, then, according to the established position of early ` Ulama, low-voiced Dhikr is more merit-worthy than loud Dhikr. As for the practice of Shaykhs in the Chistiah Order who recommend loud Dhikr for beginners, they do so in view of the spiritual condition of the seeker, as a measure of treatment, so that by voicing it any lack of alertness would go away and the heart would learn to become attuned to the Dhikr of Allah – otherwise, raising the voice in Dhikr, as such, is not desirable even with them, though it is permissible, and its justification stands proved from Hadith as well, of course, subject to the condition that, in it, there be no hypocrisy or the desire to show off (riya’ ).

The best Dhikr is silent Dhikr

Imam Ahmad ibn Hanbal, Ibn Hibban, Al-Baihaqi and others have reported from a narration by Sayyidna Sa’d ibn Abi Waqqas (Radiallahu Anhu) that Rasulullah Sallallahu Alayhi Wasallam said:

خَیرُ الذِّکرِ الخَفِیُّ وخَیرُ الرِّزقِ مَا یَکفِی

‘The best Dhikr is hidden and the best sustenance is what becomes sufficient.’

However, under particular conditions and timings, a voiced Dhikr is actually more desirable and merit-worthy. Details of these timings and conditions have been explained by Rasulullah Sallallahu Alayhi Wasallam through his word and deed, for example, calling Adhan and Iqamah with a raised voice, reciting the Qur’an during the voiced prayers with a raised voice, saying the Takbirs of Salah the Takbirs of Tashriq, the Talbiyah in Hajj etc., with a raised voice. Therefore, Muslim jurists, may Allah have mercy on them all, have reached the decision that in particular conditions and places where Rasulullah Sallallahu Alayhi Wasallam) has, by word or deed, taught us to raise the voice, voices must be raised. Under conditions and situations other than these, voiceless Dhikr is most preferable and beneficial.

Allah Ta’ala does not love those who transgress (in making Du’a’ or otherwise)

 At the end of the verse, it was said: إِنَّهُ لَا يُحِبُّ الْمُعْتَدِينَ (Surely, He does not like those who cross the limits). The word: الْمُعْتَدِينَ (al-mu` tadin) is a derivation from I` tida’ which means to cross the limits. The sense is that Allah Ta` ala does not like those who cross the limits, exactly as given in the translation. This crossing of limits, whether in Du` a’ or some other activity, has the same outcome – that Allah Ta` ala does not like that. In fact, if looked at closely, the religion of Islam is the very name of observing limits and restrictions and electing to submit and obey. Take the example of Salaah, Sawm, Hajj, Zakah and all dealings and transactions, when limits set by the Shari`ah of Islam are crossed in them, they do not remain acts of worship anymore – instead, they become sin.

Crossing the limits in Du’a’ may take several forms.

Firstly, that literal formalities, such as loud Du’a’ after salaah, raising the hands at the graveside, rhyming and other stylistic devices, are employed in Du`a’ which may spoil its essential ingredients of humility and submission.

Secondly, that unnecessary restrictions are introduced in Du` a – as it appears in Hadith that Sayyidna ` Abdullah ibn Mughaffal (Radiallahu Anhu) saw that his son was making Du` a’ in the following words: ` 0 Allah, I seek from You the palace in Paradise which is white in colour and located on the right hand side.’ He stopped him and said: ` Making such restrictions in Du`a is crossing the limit, which has been prohibited in the Qur’an and Hadith.’ (Mazhari from a narration of Ibn Majah and others)

The third form of crossing the limits is that someone makes a Du` a’ wishing ill of Muslims in general, or asks from Allah something which is harmful for them. Similarly, it is also a form of crossing the limits – as mentioned here – that Du`a’ be made in a raised voice without the need to do so. (Tafsir Mazhari, Ahkam al-Qur’an)