Well, in general, e2fsck has no idea what the kernel may have cached due
to access to the filesystem before e2fsck was run.   It's pretty much
guaranteed that inodes for /, /sbin, /lib, etc. are cached in memory,
but in general, if e2fsck needs to modify *any* metadata for a read-
only, mounted filesystem, it must force a reboot to make sure nothing
gets corrupted after the filesystem gets remounted read/write.

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fsck (boot time) forces reboot on non-critical errors
https://bugs.launchpad.net/bugs/225209
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