On January 2004, senior Hamas leader Abdel Aziz al-Rantissi offered a 10-year hudna in return for complete withdrawal from all territories captured in the Six Day War, and the establishment of a Palestinian state in the West Bank and Gaza. Rantissi said the hudna was limited to ten years and represented a decision by the movement because it was "difficult to liberate all our land at this stage; the hudna would however not signal a recognition of the state of Israel.

According to Umdat as-Salik, a medieval summary of Shafi'i jurisprudence, hudnas with a non-Muslim enemy should be limited to 10 years: "if Muslims are weak, a truce may be made for ten years if necessary, for the Prophet made a truce with the Quraysh for that long, as is related by Abu Dawud"

Then what happens after the 10 year Hudna? They build up their army and weapons during the 10 years and the battle starts again