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correction: i think i found out how to reproduce it:
File -> new -> project, start a new project. Create two new
.cpp files in it (or add them from existing files), and
most
importantly* open them both for editing, and keep them open.
Goto project options and change their build priorities to
anything (eg. 1003 and 995 anything that swaps the order of
their builds so dev-c++ has to resort them), click OK. You
may notice one of the editor windows close, then without
touching anything try closing dev-c++ and it should crash.
Atleast thats what happens with me.