If the documentation is correct, this will lead to the strictest standard:
PHP Strict standards: only variables must be passed by reference
So, I think you found the error in the documentation. Congratulations.
EDIT
It still doesn't complain if you use it with EXTR_REFS as the second argument:
~โฏ php -a Interactive shell php > function a(){return array('pwet'=> 42);} php > extract(a(), EXTR_REFS); php > echo $pwet; 42
This is strange, because references to variables defined inside a function do not make much sense to me. I think this is possible and was possibly introduced because of this option, but appears only in the document and is not applied in the code.
EDIT
I seem to be right, I found this comment in ext/standard/array.c (branches 5.3 and 5.4):
/* var_array is passed by ref for the needs of EXTR_REFS (needs to * work on the original array to create refs to its members) * simulate pass_by_value if EXTR_REFS is not used */
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