He couldn't use <c>..</c> because that would have limited him to the iso-8859-1 charset. The content of posts must be encoded using iso-8859-1 when submitted, and entities get displayed literally inside <c>..</c> tags.
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PerlMonks delivers pages in iso-8859-1, so the form content must be encoded using the same.
Hoping for the best, some browsers HTML-encode characters that aren't present in the form's charset. So if I enter "♠" into the form, my browser sends in "♠". Outside of code tags, that sequence gets echoed back by PerlMonks so you see "♠".
Of course, code tags encode HTML meta-characters including "&", so the sequence gets encoded and appears as "♠".
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I'll bet...
Easy to verify: click on the respective xml link.
(Usage of <pre> is absolutely correct in this case, btw.)
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