All perfect praise be to Allaah, The Lord of the worlds. I testify that there is none worthy of worship except Allaah and that Muhammad, sallallaahu ‘alayhi wa sallam, is His slave and Messenger.
A hadeeth has been reported to this effect in Sunan At-Tirmithi. Abu Umaamah narrated that the Prophet, sallallaahu ‘alayhi wa sallam, said, "There are three whose prayers would not be raised beyond their ears: the runaway slave until he returns, a woman who spends the night while her husband is angry with her, and a people's imaam (in prayer) whom they dislike." [At-Tirmithi]
The negation in the hadeeth does not mean that the prayers performed by such people are absolutely rejected; rather, it is a negation of perfect acceptance, as scholars underlined. Al-Mubaarakfoori wrote, "It means that the prayer is not perfectly accepted or not raised to Allaah the way good deeds are raised. At-Tooribishti said, 'They will be raised in the least manner.'" [Tuhfat Al-Ahwathi]
The reason for incurring such punishment is not confined to the wife denying her husband his right to sexual enjoyment; rather, it extends to include denying him any of his rights over her. Al-Munaawi wrote, "The hadeeth refers to the case in which a wife spends her night while her husband is angry with her because of a Sharee'ah-valid reason such as her ill manners, impoliteness, or disobedience and rebellion..." [Faydh Al-Qadeer]
Allaah knows best.