`Isha’ Prayer can be delayed till after one third of the night. However, its time can be extended till before dawn for necessity.
Ideally, one should pray `Isha’ before midnight. It is important for us to be diligent in Prayer and not put it off unnecessarily when the time arrives. Although if someone is praying `Isha’ in congregation, it is best to delay it up to one third of the night; but it is not good to postpone it later than midnight.
This is what we can infer from the traditions of the Prophet (peace and blessings be upon him).
We are told that the Prophet (peace and blessings be upon him) said, “The (preferred) time of `Isha’ Prayer extends to the middle part of the night.“
There are other traditions in which the Prophet exhorts us to delay `Isha’: “If it wouldn’t have caused hardship on my Ummah, I would have ordered them to delay `Isha’.” However, nowhere he told us to delay it past midnight.
In light of the traditions mentioned above and other valid inferences, scholars are of the view that ideally one should not delay `Isha’ farther than midnight. However, if a person could not pray before midnight, he could still pray it before dawn-as the permissible time extends up-to that time.
We read in Al-Mughni of Ibn Qudamah (a scholar of the Hanbali School),
“Ideally, one should not delay `Isha’ farther than one third of the night, if he did delay it until midnight it is fine; after midnight, it is the time of darurah (i.e. the time for those in extreme circumstances or valid excuses).”
Imam An-Nawawi (who belongs to the Shafi`i School says,
“The ideal time of `Isha’ extends up-to one third of the night; beyond that is the permissible time; which extends to the arrival of dawn.”
The Hanafi view is almost the same as mentioned above. Thus Imam At-Tahawi (who is affiliated to the Hanafi School) states,
“The time of `Isha ’can be divided into three: the ideal or the most preferred time extends to one third of the night; after which is the less preferable time which extends to midnight, still less preferable is the time past midnight until the arrival of dawn.”