“The word ‘wilful’ or ‘wilfully’ when used in the definition of a crime, it has been said time and again, means only intentionally or purposely as distinguished from accidentally or negligently and does not require any actual im-propriety; while on the other hand it has been stated with equal repetition and insistence that the requirement added by such a word is not satisfied unless there is a bad purpose or evil intent.” Rollin M. Perkins & Ronald N. Boyce, Criminal Law 875–76 (3d ed. 1982).
“Almost all of the cases under [Bankruptcy Code § 523(a)(6)] deal with the definition of the two words ‘willful’ and ‘malicious.’ Initially one might think that willful and malicious mean the same thing. If they did, Congress should have used one word and not both. Most courts feel compelled to find some different meaning for each of them.” David G. Epstein et al., Bankruptcy § 7-30, at 531 (1993).
