Google is taking a snippet from body for page titles

But only when the page has no title of its own

[Total Paranoia]

I have known for a while that Google shows a snippet from the text of a page to show a description in its results if no description meta is used on a page.

Today, I noticed that if no <title> tag is used, (if left as "untitled document") Google are taking an <h1> or other text from that page to display a title instead of showing "untitled document"

Is this a new thing? Can anyone else confirm that they are seeing the same?

A search for a domain that has no title will show this result.

Search for "untitled document" to find pages without written titles - then try another search for the domain.

[Total Paranoia]

Anyone else seeing this?