I believe this is intentional and has been the case since very early, if not 
the initial commit.

See the [code 
here](https://github.com/geany/geany/blob/0a0b4b000cf18e837b921057a461ad05a08e41d3/src/document.c#L628);
 when you open new untitled document and there's only one new/untitled document 
that hasn't been changed, it closes the previous untitled document and opens a 
new one. I'm not sure I see the point of that, but I also don't see a 
particular problem with it, unless I'm just not seeing the use case for wanting 
many new/untitled tabs open with no changes to them.

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