LEGAL PRINCIPLE: EVIDENCE LAW – Competency of Witnesses – Evidence of Single Credible Witness Sufficient to Ground Conviction
PRINCIPLE STATEMENT
The evidence of one credible witness which is accepted and believed by the trial court is sufficient to justify a conviction unless such witness is an accomplice in which case their testimony would require corroboration.
RATIO DECIDENDI (SOURCE)
"The evidence of the one credible witness which is accepted and believed by the trial court is sufficient to justify a conviction unless, of course, such a witness is an accomplice in which case his testimony would require corroboration."
EXPLANATION / SCOPE
This reinforces Principle 219. A single credible witness can sustain conviction if: (1) their evidence is credible (believable, reliable); (2) trial court accepts and believes them; (3) their testimony proves guilt beyond reasonable doubt. No legal requirement exists for: minimum number of witnesses, multiple witnesses for each element, or corroboration of credible testimony. “Credible” means: trustworthy, believable, consistent, and convincing. The exception: accomplice witnesses require corroboration (see Principle 287)—their participation in crime makes uncorroborated testimony dangerous basis for conviction. Single witness sufficiency serves: recognizing reality (crimes often witnessed by few), quality over quantity (one credible witness better than multiple incredible ones), and respecting trier of fact’s assessment. However, courts should carefully scrutinize single witness cases: assessing credibility thoroughly, ensuring no reasonable doubt remains, and noting that corroboration, while not legally required (except for accomplices), adds reliability. The principle rejects formulaic approaches requiring multiple witnesses when one credible witness proves guilt.