Unfortunately it can and has happened to me and I'm sure plenty of others. It's not a safe way to carry a rifle that cocks on opening and hunters have been known to fall over and have the bolt closed on them, some ending up with the rifle pointing at them. Not a situation you'd want to find yourself in.
I usually carry my Sako 85 with the bolt half closed and the safety engaged. The trouble with the safety only approach is that it's hard to tell at a glance whether the rifle is cocked or not. With the bolt half closed it's reassurance also for anyone you may be hunting with.
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