Va. Code » Title 19.2. Criminal Procedure » Chapter 13. Grand Juries » Article 2. Regular Grand Juries
Virginia Code

Va. Code Ann. § 19.2-202 (2026)

How indictments found and presentment made

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At least four of a regular grand jury must concur in finding or making an indictment or presentment. It may make a presentment or find an indictment upon the information of two or more of its own body, or on the testimony of witnesses called on by the grand jury, or sent to it by the court. If only one of their number can testify as to an offense, he shall be sworn as any other witness. When a presentment or indictment is so made or found, the names of the grand jurors giving the information, or of the witnesses, shall be written at the foot of the presentment or indictment.

Code 1950, § 19.1-157; 1960, c. 366; 1975, c. 495.

Notes of Decisions
Cited in 5 cases (3 in the last 5 years), 1982–2025 · leading case: Vihko v. Commonwealth, 393 S.E.2d 413 (Va. Ct. App. 1990).
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Vihko v. Commonwealth, 393 S.E.2d 413 (Va. Ct. App. 1990). · cites it 2× “Omission of the Witness’ Name from the Indictment Although Code § 19.2-202 provides for the endorsement of names of witnesses who testify before a regular grand jury, the-requirement is directory and an omission is not grounds to quash the indictment.”
Sprouse v. VA Dir. of Prisons, No. 1:24-cv-00327 (E.D. Va. Feb. 13, 2025). · cites it 4× “See Va. Code Ann. § 19.2-202 . Sprouse’s indictments were returned as “True Bills,” signed by the foreperson, and the name of Detective F.”
Thomas L. Goodman v. Chadwick Dotson, No. 1:24-cv-00944 (E.D. Va. Aug. 13, 2025). · cites it 2× “Goodman’s indictments were returned as “True Bills,” signed by the foreperson, returned by the Clerk, and the name of witness, Detective J.”
Drayton v. Dir. of the VA Dept. of Corr., No. 1:24-cv-00795 (E.D. Va. Sept. 2, 2025). · cites it 2× “Drayton’s indictments were returned as “True Bills,” signed by the foreperson, and the name of the witness, “Lauren O’Malley, APD,” is affixed at the foot of the indictment as the witness.”
Commonwealth v. Holler, 7 Va. Cir. 131 (Shenandoah Cir. Ct. 1982). · cites it 2× “Moreover, any one of its number may testify as to an offense provided he is sworn as any other witness, as expressly authorized in Virginia Code § 19.2-202. I would construe that statute to have permitted the particular juror to testify as to the procedures as she knew of them…”
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