Yeah. I'm just citing the only reason I've heard, which is that invoking vim just to update a plugin is gross. Which is kinda true - what happens if your vim config is in some bad state and doesn't start properly, your update process breaks unnecessarily (odd coupling to have). Definitely edge case-y, but a tradeoff anyway.
vim +BundleInstall! +qall
Vim still opens but could be useful if you're trying to automate vim somehow.