It might be the temptation for everything to have a category, and kind 1 are called "short TEXT notes" on the NIPs repo, or as a "simple plaintext note." in NIP-10 specifically. Neither of those suggest that images belong within the umbrella of kind 1. Clients aren't even required to render image links in kind 1 notes.

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Yeah, it's totally fine for clients not to render image links in kind 1 notes, right?

Absolutely! Voyage does this and works great!

The same would not be said about kind 20, though. If clients support it, they are expected to render the images.