I believe there's a difference between not supporting an old, non-standard-compliant browser, where you must have the same functionalities but the platform is different, and not supporting users who have turned off javascript, because in this case the functionalities themselves are different. You almost have 2 different "products" in this case.
Also, angry users are always the most vocal. The huge majority that doesn't bother (or doesn't even know how to) turning off javascript will not complain on HN.
I guess - from my point of view it would be lumped under the wider group heading of 'how much should I worry about going to significant effort supporting stuff that few of my customers will care about?'
Also, angry users are always the most vocal. The huge majority that doesn't bother (or doesn't even know how to) turning off javascript will not complain on HN.