Access
DELETE FROM (SELECT TOP 1 * FROM tbName WHERE condWhere)
Mysql
DELETE FROM tbName WHERE condWhere LIMIT 1
SqlServer
DELETE TOP 1 FROM tbName WHERE condWhere
Oracle
DELETE FROM tbName WHERE ROWID IN ( SELECT ROWID FROM tbName WHERE condWhere AND ROWNUM=1);
SQLite
DELETE FROM tbName WHERE ROWID IN ( SELECT ROWID FROM tbName WHERE condWhere LIMIT 1 );
PgSql
DELETE FROM tbName WHERE CTID IN ( SELECT CTID FROM tbName WHERE condWhere LIMIT 1 )