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
(
[0] => Array
(
[0] => apple
[1] => orange
[2] => banana
)
[1] => Array
(
[0] => blueberry
[1] => raspberry
[2] => boysenberry
)
)