2006 Hyundai Elantra Cause of loose strut bolts?

Various repairs were completed on an 06 Hyundai Elantra in November 07 due to an accident damaging the front passenger side/corner of the vehicle. Vehicle appeared to be running normally afterwards.

February 08, a knocking sound that seemed to be coming from the steering column during turns was diagnosed as "loose strut bolts that hold the right knuckle". They were tightened and the sound has not returned.

Could the loose bolts be a result of them not being tightened properly during the Nov 07 repair? This was the theory of the Feb 08 mechanic, but it seems like something like that would have shown up earlier. What other things might cause the bolts to be loose?

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Thanks for your time,
Hope Fisher