I think Kinect Adventures is pretty much set to become a 20 million seller, I think Kinect Sports has a chance of doing it too, both of them need to be on the market long enough, but I think they can do it

No game on 360 and PS3 cand do this. It's out of reach for them. Their games can not be as popular.

Even bundled with Kinect I don't think that shovelware will sell 20 millions. Kinect hype will not last.

EDIT: This post has been moderated. -d1

It's fine if you think the Kinect hype won't last, though you should give a reason. What is not okay is you calling it shovelware.

why is everyone going on about WSR being bundled? Yes, it is now but when it was first launched it wasn't bundled and sold extremely well on its own.

Can it? Theorhetically, yes, as both have an install base well over 20 million. However, will it? If Kinect maintains its momentum and Adventures remains bundled, then it is possible. However, given that there are a grand total of 4 games to crack 10 million (and 2 fall out before reaching 12 million) on one platform not published by Nintendo, it's very unlikely without the Kinect scenario above. If San Andreas can continue selling well in developing areas for a little over another year, it may be able to be the first Sony platform game to crack 20 million. (I phrase it this way as Kinect may propel Adventures to cross before it.)

Either way, I think it will be interesting to watch. My gut wants to tell me that San Andreas won't make it (stopping around 19.5m), and that Kinect Adventures may lose its bundling status (lifetime ending about 15-16m) to allow other games to shine in the light.

Just because you feel that way, doesn't make it so.  It's a completely valid opinion to exclude games that have all or a majority of its sales due to bundling.  Personally I would exclude Wii Sports, WSR, Wii Play, and Kinect Adventures.  Wii Fit could also go into that category, depending on whether or not you believe the game sold the board or vice versa.

So for me, that leaves MK Wii and NSMB Wii as the only true 20 million sellers based on the selling power of the game itself.

It was also bundled with WM Plus , so it falls into the same category as Wii Play.

Your first sentance is exactly what I say to you, the site here counts Wii Sports as highest selling game and I think the record books do as well.

I don't have a problem with that, I was just saying that both are valid opinions. 

Because we don't track minesweeper!