It can be. Sometimes the requirements are complex so any expression of them in code would also be complex. Then another person sees this complex code and automatically assumes that it is bad and should be made less complex while completely ignoring the fact that it would break the requirements. And to the person who is now going to interject that the requirements should be simpler. I am all for that if possible, but in many cases it is not. E.g., if they are written in contracts. Of course, bad programmers will create complexity where none is needed.