Hi,
Ideally yes, you have to create a test case script for testing the BAPI if you are sending it for user testing.
During internal testing also, you have to follow the process as if the user is testing it.
For technical and functional people (Consultants) testing is possible even in SE37 itself by feeding in the required inputs and then analysing the outputs, though I am not sure whether it is suficient for every BAPI you are trying to test.
Hope this information helps you
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