Not necessarily. According to some heroic japanese literature the combat is already decided when the swords are drawn. In that case the duel could be fought out with the contestants staring each other out with extremely low bids (Flicker of an eyelid, 1 AP; change centre of gravity, 2 AP), until either one reaches 0 (or less) AP. The drawing of the sword and cutting down the enemy is just a coup de gra´ce, which can be as low as 1 AP and still kill.
Applicable edges could be an enhancement from Tea Ceremony, Meditation, or perhaps a Reputation for winning duels.
-- Henrix
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