Honestly I kinda feel the opposite, that there's really nothing useful in requiring a photo for any kind of return. @robbie31415 I almost said that in reply to you earlier but figured it would be belaboring a trivia point, when you gave a perfectly workable answer to the real question of the OP.
But for real though, can you cite any reason why you think eBay requires it for INADs, or why it's a good idea? -So, yes, on the surface it's a no-brainer that the buyer should need to prove that something is not as described ..... but prove it for what outcome? -To get a free return label? That's automatic, as long as there's a photo of something (could be a boat full of dead ducks instead of a t-shirt https://community.ebay.com/t5/Selling/Ducks/td-p/32383142 ) . To prompt the seller to issue the refund when it gets the delivery scan? That's automatic too.
-Now if the buyer sends back something other than what the seller sent, the seller may have recourse, but that's upon seeing what's in the box, and at this phase it has nothing to do with the photograph. The photograph could have been of the actual item sold, with or without any signs of damage or other difference from the listing photos, but so what, if the buyer packed some whole other thing to ship back?
Funny thing, that return I had a few months ago (I think you were in thread), the scammer took a blurry ultra-closeup of something turquoise blue, not the turquoise earrings they bought, because those hadn't even been delivered to them yet (!). But the reason eBay denied their refund and closed their account wasn't because of their photo; it was the hard-referenceable difference in time between their return filing and the USPS tracking timestamps (and maybe my photograph of the plastic pebbles they sent back).
As for capturing damages or differences when they ARE a legit cause for the buyer to file an INAD, I'm kind of surprised eBay puts this burden on them, in contrast to their usual buyer-favoring tendencies. It is theoretically possible for a buyer to have no camera (I didn't have one for a few days just last month), or to not know how to transfer photos from smartphone to "the computer" (elderly people). Also, if photographic evidence is required for 'X' it should also be required for 'Y' but while capturing the fragmented pieces of a broken vase is easy, capturing scratches on a shiny gemstone is not, and failing to do so, a buyer might think they can't do a return (and if they have an unscrupulous seller, they might be happy to let them think that).
Just saying, the photo requirement isn't the thing that would stop a scammer from abusing the MBG, but it could be the thing that stops a good buyer from using it legitimately, and then just never coming back to eBay. If you can cite a good reason to require it I will happily eat humble pie, because I don't take pleasure in eBay being illogical. And I wonder, do you know if Amazon, Etsy or any of the other platforms require return photos?
