Definition of a quirky update

mo-mhi :

Based on Itzik Ben-Gan's article in ITProToday

Microsoft’s implementation follows the physical data independence principle, and therefore does not guarantee that you will get the data back from a query in any particular order unless you add an ORDER BY clause in the outer query. A similar violation of the principle is when people update data and the solution’s correctness relies on the data being updated in clustered index order (do a Web search on “quirky update” to see what I mean).

I tried to find what a quirky update means but in vain. I am looking for an example to understand the concept.