They might, just might, get away with it if the lid is a nicely cooked shortcrust lid, crimped to the edges of the dish and baked with it.
Don't get me started on those overcooked puff pastry monstrosities that are just rigid thin flakes of tastelessness that end up getting spread all over the table and make it look like I'm not house-trained yet... The kind where they've clearly got the dish of casserole out of the freezer, nuked it in the microwave, and slapped on a separately 'cooked' lid.
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