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I would believe a model release is necessary because it is a naked buttocks. Buttocks is generally accepted as a private part of the human body. This one is uncovered. All private property requires a release.
As I cannot identify an individual, I think that the release is unnecessary.
I have them sell it without release here.
In many countries it is illegal to publish intimate photographs without concent. This can be a serious crime. In the UK the penalty is up to two years in prison.
Also, given the nature of the photograph, and identity of the photographer, the model will surely be able to identify themselves. So a release is also needed for this reason.
Read what I wrote.
Sometimes error do occur. It is still not too late for rejection. If I were in your shoe, I'd call that an error, and submit the model release for the one it is requested for. This photo is not even fit for general view. This is a safe search image.
Test_screen is right. In my country public exposure like these are illegal, except you're at a resort that is licenced to operate accordingly. And oh, If I'm correct to say both images are of the same person, then the she can identify herself.