WHQL doesn't even do that, all Microsoft does is look at a bunch of logs generated from the manufacturers testing. Microsoft doesn't do anything for WHQL really, they basically just take the manufacturers word for it. Easily sail through. It's happened before, nVidia messed up a driver update back in the G92 era, the driver wouldn't spin up the fan and the card would overheat extremely quickly. It could be a similar issue happening here.