Any statement may be unreliable because of defects in the perception, memory, sincerity, or ability to narrate clearly, of the maker of the statement. Suppose that a witness, W, states in his or her testimony that ‘The car I saw driving away was red’. This statement may be unreliable because (1) W may have perceived the car to be red when it was in reality of some other colour; (2) W may have genuinely forgotten that the car was of some other colour; (3) W may be lying; or (4) W may be trying to say that the car was of some other colour, but be lacking in the ability to narrate this clearly. In this situation, because the statement has been made in court by the person who witnessed the event, it will have been possible to observe his or her demeanour at the time of making the statement. Further, the statement is likely to have been a sworn statement. Finally, it would be possible to subject the witness to ‘contemporaneous’ cross-examination in relation to the statement. Such crossexamination would, it is said, assist in exposing any defects in the witness's perception, memory, sincerity, or clarity of narration. (Choo, 2018, p 264)