Well, everything is relative (profound, huh?). Theoretically could get one .303 slug in the tail, run out of fuel, brilliantly evade pursuers, ditch, and ... count as a kill?
Same problem as proximity kills, I guess. And the game is weighted to give people kills with the benefit of the doubt.
Used to think the Supreme Court decisions were close at 5-4, but Aces High jurors have just as close a division of opinion on many things.