One-Testimony Sufficiency Principle
✅ I. Introduction
In criminal trials, the “One-Testimony Sufficiency Principle” refers to the legal doctrine that the testimony of a single trustworthy witness is sufficient to convict an accused, even in serious offences — provided the testimony is credible, cogent, and consistent.
This principle stems from the Indian Evidence Act, 1872, and has been upheld consistently by the Supreme Court and High Courts of India.
📜 II. Legal Foundation
🔹 Section 134 of the Indian Evidence Act, 1872
“No particular number of witnesses shall in any case be required for the proof of any fact.”
This means:
The law does not insist on a specific number of witnesses.
Even one witness, if found wholly reliable, is sufficient to establish a fact.
Quality of evidence is more important than quantity.
⚖️ III. Judicial Interpretation — Landmark Case Laws
Let’s look at more than five major cases where courts have applied or explained this principle:
1. Vadivelu Thevar v. State of Madras, AIR 1957 SC 614
Facts:
Conviction was based primarily on the testimony of one eyewitness.
Judgment:
The Supreme Court classified witnesses into:
Wholly reliable
Wholly unreliable
Neither wholly reliable nor wholly unreliable
It held that if a witness is wholly reliable, conviction can be based on his/her testimony alone.
Key Principle:
✅ One trustworthy witness = Sufficient for conviction.
🚫 Corroboration not needed if witness is credible.
2. Anil Phukan v. State of Assam, (1993) 3 SCC 282
Facts:
A murder conviction was based on a single eyewitness account.
Judgment:
Court reaffirmed that a conviction can rest solely on the evidence of a single eyewitness, if the court finds it trustworthy.
Key Principle:
Quality over quantity — the credibility of the witness is the deciding factor.
3. Harbans Singh v. State of Punjab, AIR 1962 SC 439
Facts:
Only one witness testified to the entire occurrence.
Judgment:
The Supreme Court emphasized that under Section 134, one witness can prove a case if found reliable. There is no requirement of multiple witnesses under law.
Key Principle:
No numerical strength required — even solitary evidence is sufficient.
4. Lallu Manjhi v. State of Jharkhand, (2003) 2 SCC 401
Facts:
Conviction was challenged on the ground that only one eye-witness was produced.
Judgment:
Supreme Court rejected the appeal and upheld the conviction. The Court stated that law does not demand plurality of witnesses and that solitary testimony can be the basis for conviction.
Key Principle:
What matters is whether the witness inspires confidence.
5. Joseph v. State of Kerala, (2003) 1 SCC 465
Facts:
The trial court convicted the accused based on the testimony of one eyewitness. High Court reversed it, doubting single-witness evidence.
Judgment:
Supreme Court restored conviction, holding that if the sole witness is credible, there is no legal bar to conviction.
Key Principle:
Witness credibility is paramount. Courts should not discard evidence merely because it is solitary.
6. Ramratan v. State of Madhya Pradesh, AIR 1997 SC 786
Facts:
The accused was convicted based on one person’s testimony who claimed to have seen the murder.
Judgment:
Supreme Court upheld the conviction, stating that there’s no rule of law or prudence that requires corroboration in every case.
Key Principle:
Testimony of one honest witness, if trustworthy, is legally sufficient.
7. Ramesh Krishna Madane v. State of Maharashtra, (2019) 3 SCC 220
Facts:
The main evidence was of a single child witness.
Judgment:
Court ruled that even child testimony can form the basis of conviction if found natural and believable, regardless of age.
Key Principle:
Even one child witness can suffice if found competent and truthful.
🔍 IV. When is Corroboration Needed?
While not legally required, corroboration is advisable in the following situations:
| Situation | Why Corroboration Helps |
|---|---|
| Witness is a child | To ensure reliability |
| Witness is interested/related | To rule out bias |
| Testimony is against normal human conduct | To cross-verify unusual claims |
| Witness has inconsistencies | To test credibility |
| Cases involving capital punishment | Courts prefer extra caution |
But even in such cases, if the court finds the testimony reliable, corroboration is not mandatory.
⚠️ V. Caution: Unreliable or Tainted Witness
If the sole witness is found to be:
Hostile, or
Contradictory, or
Motivated or interested, or
Unnatural in narration,
Then court may require corroboration or may even discard the testimony.
🧾 VI. Conclusion
The One-Testimony Sufficiency Principle is a well-established doctrine in Indian criminal jurisprudence. It empowers the courts to convict solely on the testimony of a single witness when:
The witness is credible and
The testimony is consistent, natural, and trustworthy.
This principle upholds the flexibility of the judicial system while ensuring justice does not fail merely due to lack of numbers.
✅ Key Takeaway Quote (from Vadivelu Thevar):
“A conviction can be based on the testimony of a single witness provided he is wholly reliable.”
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