A 40 handicapper, who is new to golf, is likely to improve and ultimately see a significant drop over time. Therefore, it is not unusual that at least one 40 handicapper out of many could shoot a high score. For example, imagine a field that includes 50 golfers who play off 40. It would certainly not surprise me to see the best score of those 50 golfers to be high, say 48 points as an example. Imagine the same field including 50 golfers who play off scratch. Is is equally likely that the best score for the scratch golfers would be 12 under gross to get 48 points?
Note, the smaller the field, the more chance a lower handicapper will win. Because their consistency will likely see them shoot a decent score, better than many inconsistent scores from high handicappers (generally low), so long as a higher handicapper doesn't have a blinder.