‘Abdullāh ibn Shaqīq (may Allah be pleased with him) reported: I asked ‘Ā'ishah: "Did the Prophet (may Allah's peace and blessings be upon him) pray the Duha prayer?" She said: "No, unless he came back from being away."
‘Ā'ishah (may Allah be pleased with her) was asked whether the Prophet (may Allah's peace and blessings be upon him) prayed the Duha prayer. She said that he only prayed it when he returned from a journey. This shows that the Prophet (may Allah's peace and blessings be upon him) was not a consistent observant of the Duha prayer. He would pray it occasionally, but not consistently, so it would not be made obligatory on the Muslims, as some narrations indicate. However, there are other Hadīth which suggest that one may observe the Duha prayer regularly.