Yes — and this is settled law that applies in full force in Gujarat's courts including Vadodara's district courts and the Gujarat HC. The Bharatiya Sakshya Adhiniyam 2023 — which has replaced the Evidence Act — sets no minimum number of witnesses for a conviction. What matters is the quality of testimony, assessed against the standard of proof beyond reasonable doubt, not the quantity of witnesses examined.

The governing authority is the Supreme Court's decision in Vadivelu Thevar v. State of Madras, which classified witnesses into wholly reliable, wholly unreliable, and those who fall between — and held that a witness in the first category is sufficient to convict even if they are the only witness examined. A victim's testimony in a serious personal offence, if it is consistent, credible, and inspires genuine judicial confidence, can and does ground a conviction in Gujarat's courts. Conversely, even multiple witnesses who are inconsistent, interested, or internally contradictory cannot secure a conviction — quantity does not substitute for quality.

What this means for your defence is that the battle in a case relying on a single or small number of witnesses is fought entirely on credibility, and cross-examination is the primary weapon. Your counsel must probe every inconsistency between the witness's Section 180 BNSS police statement and their court testimony, expose every partisan motive or interested relationship with the complainant, highlight every element of improbability in the narrative, and demonstrate where independent corroboration — physical, forensic, digital, or circumstantial — is entirely absent. If those challenges succeed and reasonable doubt remains at the end of all the evidence, acquittal follows regardless of how few witnesses were examined. Do not be comforted simply by a thin prosecution witness list, and do not be automatically alarmed by a single credible witness. Everything turns on how that witness holds up under examination — and that examination must be carefully prepared. The criminal trial advocates at the Vadodara panel of Aapka Legal Advice can plan and conduct this cross-examination.