That may well be the case at a service, very handy, and almost perfect timing for bringing it into the workshop from the car park to do a check. However it is much more likely to be going straight onto the lift and setting up to drain for a change with a standard n-litres refill.
Unfortunately it is not all that practical in daily life.
You drive to work or going out or home; are you going to wait five minutes by the car to read the oil? No. Usually you go inside, late for meeting or whatever or drop shopping and have a cup of tea. Then remember the car is cold again, and it’s begun to rain, “what a pity, never mind”.
Most convenient is when you know its going to be a long journey.
And being sensible you choose a suitable time in the dry before setting out to check other things as well; tyres, washer fluid, radiator, steering and brake fluids, brake lights as well as the others, and of course the engine oil. All cold, all done in just a few minutes, mostly a quick glance, except the washer always needs a top-up which is why the refill-bottle was close to hand with the bit of clean kitchen paper for wiping the dipstick.
Cold check is practical for day to day.
Warm check is required mostly after a refill, usually if you don’t know exactly how much to put in and need to run it to make sure it’s everywhere it should be, but not leaking.
But a 1 litre margin is so wide, does it really matter? Cold will do.