Comment # 4 on bug 1226043 from Luis Henriques

Here's my understanding of what happens: there was an application (or
applications) that had files open and those files were deleted while still
open.  Which means that these files were added to the 'orphan files' list.  And
the power outage happen while this list still had files in it.  After a reboot,
the e2fsck tries to clear this list but doesn't clean the inode that manages
the list itself.  When the kernel tries to mount it, it correctly detects the
filesystem still requires recovery and, because it is being mounted read-only,
it can not do the recovery itself and fails.  Later, when you manually run
e2fsck it will finally do the full recovery and the filesystem can then be
mounted.

All this to say that this seems to be a bug in e2fsck for which I've sent out a
fix upstream[1].  Hopefully it won't take long for a fix to be merged.

Again, thank you for your report.

[1]
https://lore.kernel.org/all/20240611142704.14307-1-luis.henriques@linux.dev/