Papers may not meet the standards for publication but still be useful. For example, I have a paper with 50 citations that is having difficulties getting published (either "not novel enough" or "not motivating"). There's also a randomness to review, as NeuralIPS has continually demonstrated.

I should also mention that you can also pad your citations this way and build your h-index. It is metric hacking, but if it isn't too egregious this is normal. Classic example of Goodhart's law.