Non-consistent cyclical reference handling in JQL

Steps to reproduce (example coming from real customer case):

Create the following basic filters:
A: status=Closed
B: createdDate<= now() AND filter = A
C: filter = A and filter = B

In JIRA 4.0.1:

• Searching for filter = A and filter = B works
• Searching for filter=C also works.

In JIRA 4.4.5:

• Searching for filter = A and filter = B works
• Searching for filter=C does not work, producing

Field 'filter' with value 'C' matches filter 'C' and causes a cyclical reference, this query can not be executed and should be edited.

Test scenario
The following filters run fine on JIRA 4.4.4:

a: status=Open
b: assignee=charlie and filter=a
c: createdDate<startOfDay() and filter=b
d: filter =c and project=JSP-131327

Does this mean that the first example is indeed considered to be a circular/cyclical reference? If so, why does filter = A and filter = B work while C (that equals filter = A and filter = B) does not?