I understand that prior to SQL Server 2005, you could \"trick\" SQL Server to allow use of an order by in a view definition, by also include TOP 100 PERCENT>
I have seen other code which I have inherited which uses SELECT TOP 100 PERCENT
The reason for this is simple: Enterprise Manager used to try to be helpful and format your code to include this for you. There was no point ever trying to remove it as it didn't really hurt anything and the next time you went to change it EM would insert it again.