This actually doesn't even make sense from how their network handles traffic. If you're superbanned, which most everyone is nowadays, you'd never even auth the server. Doesn't matter what mode you're in, the initial request would simply be denied.
Second, the timing of his 'unbanning' is way too close to someone trying to go into eShop during maintenance, which would bar access, doing something stupid in the meantime, fucking up, recovering into 6.0.0 from the update server, and then going online long after the maintenance ended. You don't go into the eShop and immediately get banned, that's not how this works and so I don't think he actually understood the error he got.
Recovery mode wouldn't supercede the tls-certificate. The cert comes first to ever even talk to the server. Banned certs are blacklisted from authenticating, so they'd never relay any information to Atum about Recovery Mode to then somehow get itself unbanned. The only way this works is if he just had a dauth ban but he's provided zero evidence to indicate what ban he even had.
But Atum nor their servers have any reason to overturn a dauth ban because it doesn't impact the ability to fetch firmware updates.
So this makes fuck-all sense.