According to https://wiki.sei.cmu.edu/confluence/display/c/FIO37-C.+Do+not+assume+that+fgets%28%29+or+fgetws%28%29+returns+a+nonempty+string+when+successful, bugprone-strlen-in-array-index checker is created.
The checker checks for the usage of strlen() on an array within it's own subscript operator. The main issue in the ticket is not the usage of fgets(), but rather the resulting write-outside-array-bounds error. This could occur if the array contains binary data and the terminating '\0' character is read into the array.
The check helps to narrow the scope by guarding against the usage of strlen in the subscript operator.
While certainly not natural, if we're already here, it wouldn't take more than a few additional lines to match the equivalent but "expanded" version of array indexing: