One small difference, is that choosing the kernel from the boot menu is done before unlocking the encrypted drive, so no recovery keys would be necessary. And yes, choosing an entry from a menu (which automatically appears when the last boot has failed) is simpler than entering recovery mode and typing a command, even without disk encryption.
A better analogue would be a bad update on a non-kernel package which is critical to the boot sequence, for instance systemd or glibc. Unless it's one of the distributions which snapshot the whole root filesystem before doing a package update.