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I'm specifically thinking of operating systems where devhelp is not present. Unit tests for this situation should also exist.
I don't think that not having devhelp will be a problem at all. The real problem can be if the parser is doesn't handle gracefully missing or empty gtk-doc directory.
Devhelp is definetely not needed for /usr/share/gtk-doc to be present. It's a universal format generated by the gtk-doc http://www.gtk.org/gtk-doc/ tool and can be read with plain browser too. The index files which are used by devhelp are shipped regardless of whether devhelp is installed, much like html files are shipped without checking for browser installed.