The doctype in that page is not what I would expect to see from a typical CGI.pm output, it lacks the usual version numbering and "strict", "transitional", etc information. That is causing the validator to assume the worst about the page. And I don't see anything on that page that wouldn't validate other than the header itself, unless BGCOLOR wasn't a valid attribute in 2.0.
FWIW, I just submitted one of my own CGI.pm-made HTML docs and found that it does not validate, but because the header says the doctype is XHTML basic, and the header itself uses the lang attribute, which is not in basic apparently. So your point is perhaps valid, but this may even be fixed in newer versions of CGI (I'm on whatever ActiveState included with ActivePerl).
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