Curious for what systems this does not work? I start a lot of my shebangs with `#!/usr/bin/env <app>` such that I can rely on PATH for resolving application locations.
If the first line of a file of shell commands starts with the characters "#!", the results are unspecified.
So it's basically all down to convention, but one that's been followed long enough that you can rely on it. I still don't count on shebang taking more than one argument to the command though.