Technique H25 / real life

Hello accessibility enthusiasts,

I would like to have your opinion about the following point related to 
technique H25 <http://www.w3.org/TR/WCAG-TECHS/H25.html>.

The "procedure" section asks to look for the title element in the head 
section. From a strict point of view, if a title is in the body, this 
technique should be failed. *But*, in such a case, browsers (at least 
Firefox, Opera and Chromium) do catch the title and present it to the user.

That being said, from your point of view, is technique H25 still failed ?

Thank you for your answers !
Matthieu

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