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For one, it depends which definition of "true meditation" you're thinking of. Adyashanti has a method he calls "True Meditation", which is in the "do nothing" class of techniques but it has a not-doing kind of focus to it (or "non-interference with the present moment" as he calls it). It's not a low-importance kind of non-doing though, and though it tends to become restful as one progresses, the path to getting there is not necessarily restful. It seems to be similar for other do-nothing methods, such as the Zen practice of Shikantaza.

GP cites watching a movie while one's mind is wandering as an example of Niksen. That doesn't seem to fit any definition of meditation I'm aware of.