There's a change of heart on this between RFC4627 and RFC7159:
RFC4627:
A JSON text is a serialized object or array.
JSON-text = object / array
RFC7159:
A JSON text is a serialized value. Note that certain previous
specifications of JSON constrained a JSON text to be an object or an
array. Implementations that generate only objects or arrays where a
JSON text is called for will be interoperable in the sense that all
implementations will accept these as conforming JSON texts.
JSON-text = ws value ws
No philosophical or practical justification is provided for this change of heart. The earlier version probably makes more sense as it consistently dictates that both a singe list element and a single map element (a pair or tuple) be contained. The second version allows only a single list element to be uncontained.