The only use I've seen is incrementally sorting large arrays during brute-force search of said arrays, since that is approximately free and brute-force search is pretty efficient and fast on modern CPUs. Set a "sorted" flag if/when the array is eventually sorted.

The idea was that the vast majority of arrays in a large set are not searched often enough to justify the cost of sorting them and sorting is an expensive operation if you are computing on a deadline. You also don't always know which ones will be heavily searched ahead of time. Using bubblesort, only the heavily accessed arrays end up sorted but as a side-effect of search rather than having separate heuristics to decide when/what to sort.