When a drive is opened up it inevitably causes additional damage making data recovery more difficult at best and impossible at worst. When a drive comes into us that has already been opened we must first spend time checking the drive in our clean-room chamber before powering up the drive and running diagnostics to minimise the possibility of further damage being done because of internal damage and contaminants.
Common scenarios resulting in drives being opened and this charge being applicable would include:
You can see the drive sticker has been removed indicating the drive has been opened.
You can see the screwdriver holes in the sticker indicating the drive has been opened.