Look at the pthoto at top right of what I supplied.
There is a horizontal bar emerging from behind Biden's cheek and going to the user's right.
This is the frame of the UPPER sash.
You can tell, because at the extreme right of the picture, it is contiguous with the portion of the sash going *up*.
Compare it to the window to the right hand side of the 0moeba picture. Same horizontal line, same dark strip across it, but there is a slight difference in color distinguishing it from the upper sash, that's how we know 0moeba's horizontal line is the lower sash.
Look at the window behind President Trump. Same dark line underneath the horizontal bar, but you can see the inner face of it (think of the inner rim of a picture frame) clearly contiguous with the lower window frame going down; and a clear change in color between the vertical sash at the right going above this frame, and the vertical part of the lower window frame going down.
Oh, and check this out.
Remember what you said about
For the right window the grid of the upper (outer) sash will appear slightly to the right,
Look at your pic again.
You're WRONG. Look at the middle window in that picture, and even more, the window to the far left of that picture.
Clearly the upper window there is the outer. And those sashes appear to the left, not the right.
I do believe you typed carelessly, or your assertion is muddled.
The way to tell upper from lower, is whose vertical sashes are physically contiguous with the cross bar. This is true across ALL pictures.