Code reviews are generally public and visible to the entire team and often even to other teams. While it's true that the reviewee may not be able to distinguish the two cases being considered, there may be other developers on the team or in the company who witness the review and can make the distinction. In fact, this can cause the "toxic reviewing" practice to spread to other experienced senior developers, who may see others with similar positions doing the same thing and then feel they must do it too in order to signal that they are, in fact, senior.