R. v. N.L.P., 2013 ONCA 773
[25] In R. v. C.(H.), 2009 ONCA 56, Watt J.A. explained the difference between credibility and reliability, at para. 41:
Credibility and reliability are different. Credibility has to do with a witness's veracity, reliability with the accuracy of the witness's testimony. Accuracy engages consideration of the witness's ability to accurately i. observe; ii. recall; and iii. recount events in issue. Any witness whose evidence on an issue is not credible cannot give reliable evidence on the same point. Credibility, on the other hand, is not a proxy for reliability: a credible witness may give unreliable evidence: R. v. Morrissey (1995), 1995 CanLII 3498 (ON CA), 22 O.R. (3d) 514, at 526 (C.A.).
[26] Another relevant authority is R. v. Sanichar, 2012 ONCA 117 (CanLII), [2012] O.J. No. 748 (C.A.), appeal allowed 2013 SCC 4. The Supreme Court adopted the reasons of Laskin J.A. who dissented in this court. He noted, at para. 72 of his decision:
[A]lthough credibility and reliability are distinct concepts, they both involve factual determinations that, as my colleague notes, attract significant deference from a reviewing court: see R. v. R.W.B. (2003), 2003 CanLII 48260 (ON CA), 174 O.A.C. 198, at para. 9. An appellate court should not interfere with a trial judge's assessment of the reliability of a complainant's evidence simply because it would have arrived at a different result.
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