This was clearer in the 1996 code. NEC-1996 Rule 250-114. Continuity and Attachment of Equipment Grounding Conductors to Boxes.
Where more than one equipment grounding conductor enters a box, all such conductors shall be spliced or joined within the box or to the box with devices suitable for the use.
Note that NEC-1996 required joining grounding conductors even if the circuit conductors were not spliced in the box. This may be the reason for the change, to eliminate grounding conductors associated with circuits that are pulled through the box without splicing.