In the wild, hopefully not, but I do remember coming across /bin/sh executing csh in an obscure RTOS-ish / proprietary flavor of Linux that we were prototyping at a previous employer. Would've been around 2008. I can't remember the variant, but I remember being caught off-guard by it.
AFAIK /bin/sh is standard; if you cannot trust that /bin/sh is a Bourne-like sh, you might as well have to assume /usr/bin/env can not be what it was meant to be too.
