I suspect it is far more common than we would like to think!Wonder what percentage of sparks have cut through a live cable that they 'knew for certain' was dead?
If you are cutting a cable where you can see the end and have just proving it dead, probably not. But if you have isolated a circuit and proven it dead in order to cut in to add something half-way along, then you can't be so sure!
That is possibly one of the few cases with a non-contact indicator might help to show the cable is not as dead as expected, but as they can't be trusted it would definitely be a case of insulated cutters and keeping one's face well back just in case.
Of course, if it is a high current conductor like a sub-main then you really ought to have some arc-flash PPE in use; at the very least some heat resistant leather gloves and a face mask.