existence of a hospital-issued abortion certificate might support a reasonable inference
that the abortion attested to in the certificate was voluntary and not procured by
government force. Thus, while the abortion certificate might support the conclusion that
Chen had, indeed, undergone an abortion, hardly an unusual event in China given the
government’s strong push for population control, it has no probative value in establishing
that any such abortion was involuntary.
Corroboration is not necessarily required to establish a petitioner’s right to asylum,
and relief may be granted solely on the credible testimony of the applicant. 8 C.F.R.
§ § 208.13(a) and 208.16(b). In asylum and withholding of removal cases, however, the
BIA has adopted rules which require corroboration in instances where it is reasonable to
expect such proof from a witness and there is no satisfactory explanation for its absence.
In re S-M-J-, Interim Decision 3303 (1997), available at 1997 WL 80984. These rules
have been sustained by this Court in Abdulai v. Ashcroft, 239 F.3d 542, 551-552 (3d Cir.
2001), which observed that even where an applicant is credible, corroboration may be
required if the applicant is to meet her burden of proof. Id. at n. 6.
The internal consistency of a witness’s testimony, its consistency with other
testimony, as well as its inherent (im)probability are important factors in determining
credibility, although excessive focus on insignificant testimonial inconsistencies to
support a finding of lack of credibility may not be justified. See Gao v. Ashcroft,
299 F.3d 266, 272 (3d Cir. 2002). On occasions the IJ’s decision seems a bit excessive in