S. 15 requires that a person has met the other person at least twice before. I have found no definition of "grooming" (headnotes do not count) and I have not found a provision criminalising those prior meetings. It is not my field and perhaps I have missed something but it looks to me that what is apparently referred to as "grooming" (and I'm still not quite clear what that is) is not of itself criminous.

Incidentally, it looks at first blush as if every person 10 years old or older who kisses a person under 13 commits an offence - surely I must have missed something there, mustn't I?

S9 also appears to contain a lacuna in that it requires "penetration" but some quite popular activities don't.