Yes, it can — and this is a point of principle that is settled in Indian law and directly relevant to your defence strategy. The Bharatiya Sakshya Adhiniyam, 2023 (the successor to the Evidence Act) does not prescribe a minimum number of witnesses for a conviction. The governing principle, long established and applicable in every court in Kanpur, is that evidence is assessed by quality, not counted by quantity.

The authoritative Supreme Court decision is Vadivelu Thevar v. State of Madras, which classified witnesses into three categories: those who are wholly reliable, those who are wholly unreliable, and those who fall in between. Where a witness falls firmly in the first category — consistent, credible, corroborated by the surrounding circumstances, and inspiring genuine judicial confidence — a court may and does convict on that single testimony, even if it is the only eyewitness. In Kanpur courts, convictions on the sole testimony of a credible victim have been upheld on appeal, particularly in serious personal offences. Conversely, even a large number of interested or inconsistent witnesses cannot sustain a conviction, because quantity does not substitute for quality.

For your defence, this principle cuts in your favour in a specific way. The battle in a case resting on a single or small number of prosecution witnesses is fought on credibility, and cross-examination is your primary weapon. Your counsel must probe every inconsistency between the witness's Section 180 BNSS statement to police and their court testimony, expose every interested motive, highlight every improbability in the narrative, and demonstrate where the account lacks independent corroboration — physical evidence, CCTV, medical records, or other witnesses. If those credibility challenges succeed, the benefit of the doubt is yours, regardless of whether only one witness or ten are examined. The experienced trial advocates and retired Sessions Judges on the Kanpur criminal panel — including retired judges who have evaluated exactly this kind of single-witness evidence from the bench — can help you understand how the specific witness in your case is likely to hold up and what the cross-examination must achieve.

So do not be comforted by a thin prosecution witness list alone, nor alarmed by a single credible one. Everything turns on that witness's quality when tested in court.