If the debtor denies the debt (owning the money) and the owner does not have a legal (sharʿī) proof, then zakāt will not be wājib on such a debt. However, if the debt is eventually repaid, then zakāt will be wājib for it on the passing of a year or by adding it with other niṣābs. Zakāt for the pervious years will not be wājib.
Zakat is not wājib on a Mukātab slave…., and that debt which the debtor refuses to pay for years and the owner does not have proof of it. [Shami Zakariyya 3/184, Alamgiri 1/174, Similarly in Hidayah 1/202, Tatatrkhaniyya Zakariyya 3/252, Bahr Raiq 2/362.]
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