I think the argument is probably:
0.) some people have been historically advantaged over each other for non-meritocratic reasons.
1.) one of the ways people have been advantaged is itself in the notability of their actions.
[0]: http://listverse.com/2013/10/14/10-groundbreaking-women-scie...
[1]: http://io9.gizmodo.com/5077952/women-who-pretended-to-be-men...
[2]: https://www.wsj.com/articles/SB10001424127887324355904578159...
[3]: https://fivethirtyeight.com/datalab/are-female-scientists-hi...
2.) Therefore, using notability as a prerequisite for inclusion perpetuates a non-meritocratic historical bias.