Yes actually it should. If you are willing to condemn him for it then it should be explicitly stated. Technically what he did didn't violate the rules.

I would also like to point out that if this guy was a company it would not have violated the rules to have his employees create and account and vote up the app. We should probably nip that in the bud before it becomes an issue. Assuming anyone planning commercial releases into this piss poor commercial environment is still considering doing so.