`Luciano Andress Martini` pointed out this lets you run `umount /` and then `fsck /dev/hda2`.  (Assuming there are no files open for writing, e.g. because the system is running in single-user mode).  This means you can use the same commands as if you needed to fsck `/home`, without requiring you to know how to remount a filesystem as read-only.  It's nice that Linux can be helpful like this, when you are trying to recover a corrupted system :-).

The other known use of this special case is in old shutdown scripts which ran `umount -a`, defined as simply unmounting all filesystems in reverse order, finishing with the root filesystem.

I'm not certain why this is implemented in the kernel, rather than in the `umount` command.  One reason might be that old kernels accepted the name of the mounted device, instead of the directory the filesystem was mounted at.  So perhaps putting the check in the kernel was considered simpler or more reliable.

The same code comment is present in early versions of Linux [including 0.99.10 (1993)](https://github.com/mpe/linux-fullhistory/blame/238327caacec57ec3c9e6a1db02370f3deec0c93/fs/super.c#L361).  On the other hand it does not seem to be a standard for traditional UNIX.  The FreeBSD kernel [returns an error instead](https://github.com/freebsd/freebsd/blob/release/11.2.0/sys/kern/vfs_mount.c#L1255), and the FreeBSD equivalent of `umount -a` stops before unmounting the first filesystem i.e. the root.  (The code is [here](https://github.com/freebsd/freebsd/blob/master/sbin/umount/umount.c#L162), but you need to understand how `for` loops and array indexes work in C :-).

The special case is not documented in the current man pages for `umount(2)` or `umount(8)`.  So the current man page implies that `umount -a` will always fail, but this is not the case.  You might guess that `umount -a` is not very widely used nowadays.

The old scripts contrast with current scripts for SysVinit, for example in Debian.  `/etc/init.d/umount_root` explicitly remounts `/` as readonly.  The rest of the mounts are processed individually, by `/etc/init.d/umountfs` and `/etc/init.d/umountnfs.sh`.

`umount -a` is not ideal on modern systems.  E.g. it is simpler to leave a `/proc` filesystem mounted so that `/proc/mounts` can still be used.  And `/dev` is usually a separate mounted filesystem, which will show an unmount error because `/dev/console` is still open.

For an example of an old shutdown script, see the reference script `etc/rc.d/rc.0` in the old `SysVinit-2.4.tar.z` / `SysVinit-2.4.tar.gz`.

    #! /bin/sh
    #
    # brc		This file is executed by init(8) when the system is being
    #		shutdown (i.e. set to run at level 0).  It usually takes
    #		care of un-mounting al unneeded file systems.
    #
    # Version:	@(#)/etc/brc		2.01	02/17/93
    #
    # Authors:	Miquel van Smoorenburg, <miquels@drinkel.nl.mugnet.org>
    #		Fred N. van Kempen, <waltje@uwalt.nl.mugnet.org>
    #
    
      PATH=/bin:/etc:/usr/bin
      echo Unmounting file systems.....
      umount -a
      echo Done.