Sometimes they come up in my search results in the Omnibar. Open tabs are in the top rank of results.
But that depends on you thinking to bookmark the page; or accepting that some things will age out of the browser history. So I guess it's kind of like a fragile bookmark: probably reliable, but not the end of the world if tab restoration failed for some reason.
Also, (I assume) tabs retain their Previous Page list, which also has some value.
Interesting. Thanks for the discussion!
That said, I'm pretty sure the Omnibar is buggy at finding tabs. I inevitably have several tabs to gmail "open". It ought to be a lot easier than it is to find /return to the last-used gmail tab, and not one of the several from previous browsing sessions. :)
There is the rare bookmark in my toolbar tabs for undetermined future stuff.