Is there scholarly disagreement regarding the liability for destroying birds, particularly those smaller than pigeons?

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There is no disagreement among scholars regarding the necessity of compensating for destroyed birds, except for a view attributed to Dawud, who held that game smaller than pigeons is not subject to compensation because of the verse stating that compensation must be like what was killed of the grazing animals (Quran 5:95), which implies these smaller creatures have no equivalent. Our evidence is the general statement of the Almighty: 'O you who have believed, do not kill game while you are consecrated' (Quran 5:95). Furthermore, the verse concerning Allah testing with game that the hands can reach (Quran 5:94) is interpreted as referring to fledglings, eggs, and small game that cannot escape, while 'your weapons' refers to the large game.