It's the worst on iPhone, because it won't even let me scroll back up to show the button to open the tabs view, I have to switch out of the browser and re-open it to be able to scroll to show.
Maybe you can two-finger pinch to shrink the web page to the grid view, then close the page from there?
Yikes, that shouldn't be possible.
Maybe you can two-finger pinch to shrink the web page to the grid view, then close the page from there?