• Collusion can arise both from a deliberate agreement to concoct evidence, as well as from communication among witnesses that can have the effect, whether consciously or unconsciously, of colouring and tailoring their descriptions of the impugned events: R v Clause, 2016 ONCA 859 at para 81

​

• The “reliability of a witness’s account can be undermined not only by deliberate collusion for the purpose of concocting evidence, but also by the influence of hearing other people’s stories, which can tend to colour one’s interpretation of personal events or reinforce a perception about which one had doubts or concerns.": Clause at para 81

​

• Once evidence is admitted, “the jury must still be warned to assess the evidence carefully and to consider whether it can be considered reliable given the possibility of deliberate or accidental tainting by collusion among the witnesses.” The jury should consider the opportunities for collusion or collaboration to concoct the evidence and the possibility that these opportunities were used for such a purpose: Clause at para 83 and 84

​

​