This doesn't follow from the robot rules as I read them.
Emphasis mine:
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Originally Posted by R52
With the exception of servos, fans, or hard drive motors permitted in R29, each actuator must be controlled by a power regulating device.
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Originally Posted by R66 C
Fans may be attached to motor controllers and may be powered from the power input terminals.
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The only other mention of fans in the rules is a limit of a 20A breaker (R48, third row of table), the description of allowed fans (R29, last row: from a KoP, or part of COTS devices).
I can find no rule that requires that a fan ever be switched off apart from a main breaker disable; the rules appear to allow it to be run directly from the output of a PDP breaker, though not quite explicitly.
G1 (generic unsafe operation) is a possibility, but this should have been accompanied with a statement as to why it was unsafe/what had to be corrected. (e.g. a large unshrouded fan is an obvious safety hazard, even if it's behind a motor controller).
Edit: No, it may not be wired directly to the battery; you do have to go through a 20A or smaller breaker per R48.