“…86 For this reason, the "hate" in hate crimes is often a misnomer. 87 Another variance is that some laws require that the perpetrator be motivated by animus (the subjective animus model), 88 whereas other laws are worded to capture the mere demonstration of hostility or prejudice (the objective animus model). The latter approach is far broader, and has been criticised, 89 as it includes cases where the offender may not have actually intended to commit the offence with a hostile motivation, but nevertheless demonstrated hostility during the commission of the offence.…”