action.inc and $stack variable

I'd like to understand the rationale behind the stack overflow guard in actions_do(). Today (D6), if I understand correctly, the code aborts when it encounters more than 35 (or the value of actions_max_stack) invocations of actions_do() during one page rendering, *even if those invocations are sequential, not recursive*. I don't think that this is what's intended. Instead, I would have expected the code to abort if there are more than 35 recursive invocations of actions_do(), which would be achieved by just adding

$stack--;

just before the return of actions_do();

I am bringing this up because my module Views Bulk Operations allows one to select an arbitrary number of nodes and to apply a specific action on each of them. The code only works currently if I set actions_max_stack to a large number, which strikes me as inelegant and illogical.