On the Number Required to Establish Taʿdīl (praise)
In his PhD dissertation, later published as ʿAdālat al-Ruwāt wa al-Shuhūd, Dr. al-Murtada al-Mahatwary (d. 1436 AH) analyses Zaydī differences of opinion concerning the number required to establish jarḥ (criticism) and taʿdīl (praise).
Among Zaydī scholars, one position treats jarḥ and taʿdīl as a form of legal testimony (shahādah) and therefore subjects them to the same numerical requirements as testimony in judicial settings, namely two upright persons or more. This view is attributed to authorities such as Imam Yaḥyā al-Hādī (d. 298 AH) and Imam al-Nāṣir al-Aṭrūsh (d. 304 AH).
Another Zaydī position holds that jarḥ and taʿdīl are not testimony but a report (khabar), and therefore the statement of one upright person may suffice, since a khabar yields presumptive knowledge (dhann), which is sufficient in this domain. This position was adopted by major Zaydī authorities such as Imam Aḥmad ibn Yaḥyā al-Mahdī (d. 656 AH), al-Amīr al-Ṣanʿānī (d. 1182 AH), and Abū Ṭālib Yaḥyā ibn al-Ḥusayn (d. 424 AH). This view was further strengthened by later Zaydī jurists, including Imam Sharaf al-Dīn al-Ḥusayn ibn Aḥmad (d. 965 AH).
After presenting these views, al-Mahatwary chooses the opinion that jarḥ and taʿdīl may, in principle, be established by the statement of a single upright person, since they function as a report (khabar) and the required standard is the attainment of dhann. However, he does not treat this as an absolute numerical rule. Rather, sufficiency depends on the circumstances of each case and whether genuine confidence is achieved; when suspicion is strong, more than one evaluator—or even extensive investigation—may be required.
He further notes that since scholars have differed and the issue allows flexibility, there is no harm in adopting any view that reassures the heart. Whenever presumptive knowledge (dhann) is achieved—even through one person—acting upon it is valid. In the modern context, he observes, even two or three people may fail to generate genuine confidence, making extensive investigation necessary, especially where there is fear of collusion or differences in creed.
Source
Dr. al-Murtada al-Mahatwary, ʿAdālat al-Ruwāt wa al-Shuhūd, p. 277-280.