Yes, here it is explained why.
Unused references
Code that keep useless references to objects that will never use again, and at the same time never drop those references; one may say those cases are not "true" memory leaks because there are still references to those objects around, but if the program never use those references again and also never drop them, it is completely equivalent to (and as bad as) a "true memory leak".
Java Native Interface
While implementing JNI functionality, you could
