[OMBUG]

It doesn't make sense to say there's an upper and lower bound on the "worst" case. If that were true, the upper bound would be the new worst case, and the lower bound would be some middle case. A best or worst case is inherently always going to be big-theta.

[ballpoint]

This talks about our ability to reach or describe the worst case, so if we say it's Ɵ(n^2), we're saying that we can tell that the worst case is at least quadratic, and it's also no worse than quadratic. We might not be so good at the math and have only discovered that the worst case was at least linear and no worse than exponential (which is true of quicksort).