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Konstantin Klima

People (especially those that use WordPress and themes) will often put whole paragraphs of text inside of a h* because their theme doesn't use classes to manipulate CSS properties, but relies on attaching those CSS properties via the h* selectors.

Meaning, for example that h1 is big and blue, while h3 is a bit smaller and yellow. So someone comes along and says "this bit of text [imagine a long sentance]" needs to be a bit larger and yellow, and they will then proceed to put that very long text (which obviously is not a heading) inside a h3 tag, just for the looks.