It would seem so but that doesnt sound right. Also notice that the odds of the battle have to be 2:1 in your favor or less.
Are you talking about experience or command stars? Because the two are entirely seperate. Experience is gained by having your general in the thick of the fighting. Command stars are gained when you win a battle. The two are seperate.
Its seemed to me that the more the odds are stacked against you them the better chance of getting stars. For example within the first 4 turns of my greek campaign i managed to get three of my generals at 10+ stars (including traits) simply by winning battles that were so incredibly in the enemy's favor. Regardless the general doesnt get the majority of his stars from the basic good commander traits. Most of the stars come from other traits like good attacker, good defender, wall breaker, etc. They can also come from the retinue such as the mercenary captain (you get him just by hiring a unit of mercenaries and he comes with +1 command).
So you might want to look into those as well.
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