Mark R. Cohen writes that 'while they are subdued' was interpreted by many to mean "humiliated state of the non-Muslims". According to Ziauddin Ahmed, in the view of the majority of "Fuqahā" (Islamic jurists), the jizya was levied on non-Muslims in order to humiliate them for their unbelief. In contrast, Abdel-Haleem writes that this notion of humiliation runs contrary to verses such as, "Do not dispute with the People of the Book except in the best manner" (Q 29:46), and the Prophetic "ḥadīth", 'May God have mercy on the man who is liberal and easy-going ("samḥ") when he buys, when he sells, and when he demands what is due to him'. Al-Shafi'i, the founder of the Shafi'i school of law, wrote that a number of scholars explained this last expression to mean that "Islamic rulings are enforced on them." This understanding is reiterated by the Hanbali jurist Ibn Qayyim al-Jawziyya, who interprets "wa-hum ṣāghirūn" as making all subjects of the state obey the law and, in the case of the People of the Book, pay the jizya.