In typing this I thought of a reason for it but will continue for any one else's input. I've never seen it before but seems quite sensible now I have a likely treason.
5 amp rated TO3 mounted through heatsink and pcb. One C terminal just bolt and nut , no electrical connection. The other is bolt , solder tag, star washer and nut and the solder tag fully swathed in solder ,bolt hole to wiring hole , merging with thick pcb trace, but only requiring to pass 5amp.
I can see that star washer could punch through the thin copper on the pcb so this method avoids that potential problem, and would constitute good practice assembly