Sure. Some structures, like an object with member arrays, will have you in a straight-jacket long before you determine where a particular value falls within the structure and how you should construct a reference to it.
Next time, try this:
$x = [['apple','orange','banana'],['blueberry','raspberry','boysenberry']]; print('<pre>').print_r($x,1).('<pre>');
The results are astonishingly different...
Array (  => Array (  => apple  => orange  => banana )  => Array (  => blueberry  => raspberry  => boysenberry ) )