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Hard to distinguish, I think.it's for protection, but to protect against low output voltage rather than high input voltage
Describes a case of possible failure. The initial capacitor voltage will be still zero, forcing the LM317 into current limit. Pulling the sense terminal up by a zener diode can destroy LM317 and zener diode immediately.However if there is a capacitor between output and ground, then there is a problem at switch-on. Without the zener, the voltage across the LM317 will initially be 60V, before the capacitor charges up.