If the code was initially a net positive (i.e. provided a feature users wanted/needed, etc.), then in a way, yes. It might be bad in the abstract in the way patching something with bubblegum is, but if it works at the time--it works.

I think the only way to argue it was wholesale bad is that it immediately and objectively sank future progress (like a fatal wound of sorts). If it made things a hassle going forward, you'd have to argue that it was so much of a hassle that it actually receded things back into a negative. Most companies rarely experience the debt that stops forward progress cold or can prove they'd be making X times more progress if wasn't for such and such debt.

That said, if you could do things in such a way that yields the desired result and causes less (there is always some, and never little) maintenance, that's ideal. The thing is, everyone is trying to code from that place. The only ones who aren't are those who can't (they really are incompetent) or those who have given into utter malaise or malice.