To prevent wrong restores and also to prevent user failure there should be a check if the target database is shutted down.
As far as I can see it will never work if the DB would be running.
to be added to the TODO list
Until we improve the remote recovery facility (with a remote agent, for example), this kind of checks is difficult and cumbersome. With local recovery it is pretty straightforward.
Theoretically, the recovery command should detect the PID file location and check if the process is up.