I'm not going to get into the subjectivity of what is or is not "sinister", but there's a more fundamental issue with the pattern you've described. Increasingly often today headlines
are defacto articles. They get shared on various social media outlets and then people start discussing the title, filling in the body themselves. When the title is 'fake', it leads to mass disinformation. This gets even worse when the title
and lead paragraph say one thing and it's only later in the article that the more nuanced reality is revealed. In that case you not only mislead the 'titlers' but also the skimmers.
I imagine readers on HN actually read articles at a vastly higher rate than e.g. Reddit or Facebook, yet on reading the comments it often becomes quickly apparent that many users, even here, do not bother reading articles before commenting on them. In an ideal world I wouldn't mind seeing misleading headlines put in the same bucket as false or misleading advertising. Of course in practice that'd be a terrible idea since this rule would simply be used for the powers that be to litigate against anything they don't like being published.