Sure It can. For example, If I'm looking for a certain stackoverflow post about a project I'm working on, I know it's be on the window with the other resources for that project, and I can remember that it's roughly on the middle right portion of that group of tabs. That narrows it down to <10 tabs to quickly check.
If I use my browser history, I'm going to have to re-filter out all of the webpages I deemed inadequate. If the tab was left open, I know it was at least somewhat useful.