Such things happen. From my experience, mainly
- by mistake (i.e., creating the same note manually again with different casing, say “Human” and “human”)
- by importing/automatic data processing—this can create a lot of similar notes with different casing
- by creating a note in Linux (which allows almost anything in a filename), and having that later processed on a filesystem with different filename casing (FAT, for instamce)
- by using “illegal” (for other OS/filesystem) characters and having these automatically removed on save (ok, not casing, but “illegal character” problem) one might end up with a dup.
Just some examples that have happened.
I still say I could live with a consistent system to be used across OSes and file systems, since normally you’d avoid such kind of duplicates.