I've occasionally missed a few when I was digging the bulbs (really small ones, where the tops had died back and I didn't think there was anything there) and they've sprouted again the next spring -- even following rototilling! And I've planted the little "bulbils" that form on the top of hardneck garlic and then just left them in the ground to make bulbs the 2nd year. But I can't see that the bulbs that are just left in the ground indefinitely like that would yield anything like what I would consider "nice" garlic
. (Maybe I'm just too fussy? Nah, I don't think so
)