I can think of only two circumstances. Perhaps someone else will think of others.
(1) When the thing they are "downstream" of is a transformer, and when there is no other breaker or other overcurrent device to protect the transformer secondary windings or the secondary feeder conductors.
(2) When the downstream panel is in a separate building, and when there is no other disconnecting means capable of turning off all power to the building.
In general, if a panel is fed from another panel, and if the first panel has a breaker that is rated low enough to protect the downstream panel, then the downstream panel does not have to have a main breaker of its own.