The qmail bounty explicitly disclaims "bugs outside of qmail", which this one clearly is. So, no.
The only reasonable policy for a shell to follow is to be entirely input-agnostic and never execute code based on the contents of an environment variable (regardless of which RFCs the contents conform to).
Even though bash shouldn't have executed the code, better input validation and RFC conformance in qmail could have prevented exploitation of bash. You know, defense-in-depth.