Steam Account Recovery

Someone made a thread earlier about something, and now I'm thinking its so easy to FAKE a recovery. The rules state: If the account gets recovered, no matter what happens you have to refund. But its absolutely 0% possible to proof that an account got recovered. So if this rule is true, any buyer can just buy an account say it got recovered and get his money back, right? Since when an account gets recovered, the email that its registered on doesn't get any notifications about an email/password change or about that it got recovered.

What do you guys think about this?