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 ʻalayhi wa sallam, is His slave and Messenger.
The scholarly difference of opinion in this regard was reported by As-Saffaareeni in his book Ghithaa' Al-Albaab. He cited the difference of opinion about saying “‘Alayhi as-salaam” for other than the Prophet, sallallaahu ʻalayhi wa sallam, and then he said: “Does the same ruling of saying 'Sallallaahu 'alayhi' to other than the Prophet apply to saying '‘Alayhi as-salaam' as far as the difference of opinion among the scholars of the Salaf (righteous predecessors) and among the scholars of our Hanbali mathhab are concerned, or rather it is only permissible to say that? In other words, is it allowed to say about anyone, '‘As-salaamu ‘ala so and so,' or, 'So and so, ‘alayhi as-salaam'? In our Hanbali mathhab, I have come to know that it is permissible because it is permissible to say, 'Sallallaahu 'alayhi' to other than the Prophet, sallallaahu ʻalayhi wa sallam; so, it is permissible to say, '‘Alayhi as-salaam' to other than him with greater reason. As for the Shaafiʻis, it was disliked by Abu Muhammad Al-Juwayni, and he forbade saying, 'So and so ‘alayhi as-salaam.' Other scholars made a distinction between saying, '‘Alayhi as-salaam' and, '‘Sallallaahu 'alayhi.' They said that it is permissible to say, '‘Alayhi as-salaam' regarding every believer, present or absent, dead or alive. You would commonly say, 'Send my salaam to so-and-so,' and salaam is the greeting of Muslims. On the contrary, invoking 'Salah' is one of the special rights of the Prophet, sallallaahu ʻalayhi wa sallam, over us. Therefore, the Muslim says in prayer (in Tashahhud), 'As-salaamu ‘alaynaa wa ‘ala ‘ibaadillahi as-saaliheen.' (Peace be upon us and upon the pious slaves of Allaah.)”
Allaah knows best.