Yups, u are correct. i tested this in Tomcat5.0.28. Looks like another inconsistency of Tomcat.
But this creates another question. Is the <body-content> a required *tag* in the TLD ? HFS pg. 467 mentions this as *REQUIRED*. However, tomcat does take JSP as the default value, if it is not present.
Tried looking in the specs, but could not find anywhere about this.