If you're saying great tests are better than adequate tests, nobody's disagreeing. But untested code puts a variety of burdens on project maintainers. I don't see why maintainers should be obliged to take on that burden when the person wanting the patch won't bother.

Also, I don't see your quoted rule in the post you're responding to. Instead I see them saying that in a specific case, they ask for tests with patches. How did you get from that specific case to such a universal, no-exceptions rule?