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 light and, in making credit findings, it is necessary to be cognisant of potentially missing context.

183 The other general point emphasised, although also made by the respondents, is that to the extent that so-called "peripheral details" of her reconstructed memory were wrong, they do not reflect dishonesty even though they may raise an issue as to reliability. As to reliability, one must not only take account of the well-known general features of human memory, but also the mental state of Ms Higgins and the well-known specific effect of trauma, and in particular sexual assault, on her memory.

184 This submission has merit up to a point, and it has informed my consideration of important, indeed critical, aspects of Ms Higgins' evidence, but, as I will explain, I am comfortably satisfied that a number of credit issues arising from a fair assessment of the evidence of Ms Higgins cannot be minimised in this way.

IIContrast with Mr Lehrmann

185 Those studying political science in the late twentieth century were inevitably introduced to the work of Hannah Arendt who discussed the importance of public truth while coining and explaining the notion of "organised lying".

186 There is a significant difference between the distortions of Mr Lehrmann and Ms Higgins. In the case of Mr Lehrmann, the untruths were all over the shop (being a form of what might be called "disorganised lying"); whereas the untruths of Ms Higgins: (a) can be placed in two temporal categories; (b) were, in the latter category, quite organised; and (c) within both categories, generally had a common thread. In 2019, this was to paint aspects of her conduct in a better light at a time when she did not wish to pursue a complaint; but by 2021 and afterwards, most were part of a broader narrative or theme she and her boyfriend wished others to believe (and, it appears, others wanted to believe).

187 Unsurprisingly, counsel for Mr Lehrmann made several detailed attacks on the credit of Ms Higgins in final submissions. But no distinction was recognised between the two periods and the different contexts I have described.

188 Ms Higgins was described "as a fundamentally dishonest witness such that the Court could not act on anything she says without independent corroborative evidence". The submission was developed by asserting that her evidence "has been so discredited, and she has been Lehrmann v Network Ten Pty Limited (Trial Judgment) [2024] FCA 369