Difference between bind vs closure in Server Actions

[AmitJoki]

In this section

There is a statement

Instead, you can pass id to the Server Action using JS bind. This will ensure that any values passed to the Server Action are encoded.

const updateInvoiceWithId = updateInvoice.bind(null, invoice.id);

We can do the following without bind and it works alright.

<form action={(formData) => updateInvoice(invoice.id, formData)}>

Is there a difference between the two?