I think it's actually basically the same. Being a clean, organized cook is probably positively correlated with making good food, but it's not strictly necessary. If someone is writing sloppy code but shipping a project of this overall quality without leaking the "low quality" of their implementation, then I wouldn't presume to call them a "bad dev" - I would probably conclude that they're more efficient than I am at prioritizing where to spend organizational energy.
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