body: I don't understand the bold text in the [OATPA 1861](http://www.legislation.gov.uk/ukpga/Vict/24-25/100/contents).
  
  
  1. How is s. 18 "in at least one respect, broader than section 20"?
  2. Are there more respects than just "one respect"? How many exactly? What are they?
  
  
  Herring, [*Criminal Law: Text, Cases, and Materials* (8 edn, 2018)](https://global.oup.com/academic/product/criminal-law-9780198811817?cc=ca&lang=en&). p. 372.
  
  
  
  > 
  > offence under section 47 because it may not be easy to demonstrate that there was a battery
  >  or an assault?251
  >  Although the Law Commission252 and many commentators are convinced by these
  >  arguments there are a few commentators who are willing to stand up for the Offences
  >  Against the Person Act 1861. One of the strongest defences of the Act is provided by John
  >  Gardner. In the following extract, he replies to some of the objections mentioned previously.
  >  He starts by challenging the claim that the Act is irrational:
  > 
  > 
  > ### J. Gardner, ‘Rationality and the Rule of Law in Offences against the Person’ (1994) 53 *Cambridge Law Journal* 502 at 503–11
  > 
  > 
  > 
  > > 
  > > The rationality argument figures less prominently in the Law Commission’s latest report
  > >  than it does in the consultation paper which preceded it. One can only speculate as to the
  > >  causes of its demotion, but its spirit certainly lives on in the draft Bill. The spirit of the argument
  > >  is captured in the Commission’s comment that ‘sections 18, 20 and 47 of the 1861
  > >  Act . . . were not drafted with a view to setting out the various offences with which they deal
  > >  in a logical or graded manner’. The assumption is that the three offences can, in substance,
  > >  be graded, and that this would be the logical way to define and organise them. Between
  > >  them they deal with matters which would most naturally be dealt with in a hierarchy of more
  > >  and less serious offences all conforming to a standard definitional pattern. The irrationality
  > >  of the 1861 Act lies in its failure to take this natural path, its failure to carry the underlying
  > >  hierarchy of seriousness over into the actual definition and organisation of the offences.
  > >  Thus, section 18 should be regarded, in substance, as an aggravated version of section 20;
  > >  and yet there are miscellaneous differences between the two sections which do not appear
  > >  to bear any rational relation to the aggravation. Likewise, section 20 should be regarded, in
  > >  substance, as the more serious cousin of section 47; and yet the two offences are drafted
  > >  in quite different terms, so that the essential difference in point of seriousness is obscured
  > >  by a mass of other, utterly irrelevant differences. If the sections were properly graded in
  > >  definition as they are in substance, then section 18 would surely cover a narrower class of
  > >  cases than section 20 which would cover a narrower class of cases than section 47; and
  > >  **yet section 47 is, in at least one respect, the narrowest offence of the three, while section
  > >  18 is, in at least one respect, broader than section 20**. That is surely irrational. The law on
  > >  such matters should be thoroughly governed, in the Law Commission’s words, ‘by clear
  > >  distinctions . . . between serious and less serious cases’.
  > >  That a section 18 offence should be regarded, in substance, as a more serious version of
  > >  a section 20 offence is easy enough to understand. Section 20 covers malicious wounding
  > >  and the malicious infliction of grievous bodily harm. Section 18 covers malicious wounding
  > >  and maliciously causing grievous bodily harm, when these things are done with intention to
  > >  do grievous bodily harm or to prevent or resist arrest. The extra element of intention required
  > >  for a section 18 offence obviously accounts for the difference between the sentencing
  > >  maxima (five years’ imprisonment under section 20 and life under section 18), and marks a
  > >  difference in point of seriousness (or potential seriousness) which the Law Commission is
  > >  rightly anxious to retain in its hierarchy of replacement offences. The Commission has not
  > >  even felt the need to explain its decision, however, to eliminate the difference in the causal
  > >  elements of sections 18 and 20. Section 20 requires that grievous bodily harm be inflicted,
  > > 
  > > 
  > > 
  > 
  > 
  > 251 In fact, in the light of *DPP v K* [1990] 1 All ER 331 there is likely to be a battery.  
  > 
  >  252 Law Commission (2014).
  > 
  > 
  > 
  
  
  
title: Offences Against the Person Act 1861 — How is Section 18 , in at least one respect broader than Section 20?