It's somehow very easy for some people to do. Just look at "
simpleflips capture taken compilation" for example.
Although I do admit that I have pressed the Home button instead of the (+) button on my Pro Controller more often than I'm willing to admit.
Other than that, pressing it on a regular Joy-Con *on purpose* is borderline impossible, let alone by accident, so pretty sure this is very controller-specific.
As for PlayStation 4/5 controller, the lack of a proper Start/Select button is really annoying, so I can see how you could press it by accident (although I'm only using it on PC, so no idea what it would do on a real PS4/PS5, as I don't have one).