Starting with PHP 5.3.4, the prototype checks were relaxed and it’s possible for implementations of this method to return by reference. This makes indirect modifications to the overloaded array dimensions of ArrayAccess objects possible.
A direct modification is one that replaces completely the value of the array dimension, as in $obj[6] = 7. An indirect modification, on the other hand, only changes part of the dimension, or attempts to assign the dimension by reference to another variable, as in $obj[6][7] = 7 or $var =& $obj[6]. Increments with ++ and decrements with — are also implemented in a way that requires indirect modification.
While direct modification triggers a call to ArrayAccess::offsetSet(), indirect modification triggers a call to ArrayAccess::offsetGet(). In that case, the implementation of ArrayAccess::offsetGet() must be able to return by reference, otherwise an E_NOTICE message is raised.
I really don’t know how came up with this, but: Congrats, now it throws an E_NOTICE not stating, that the array was modified.
So it’s either intentional or a bug.