Well yes, that's fair. The JAA exams I passed circa 2008 were bloated with excess material, and often contained poor answers that forced you to think your way into the examiners head, rather than simply provide correct answers to questions, and from what I've heard it has got worse. By comparison, I did an FAA CPL a couple of years ago and it was totally the other way - the TK/written was in most technical aspects frankly much too shallow, although it compensated in large part by the strict and relevant oral. I also do not accept the need for the massive exam load imposed upon people (in Europe) now, which is even worse than the daft exam loads I had to pass 13ish years ago.
So there are two "no excuses here". There's no excuse for not learning the subject, but no excuse for the mismanagement and bloating of the present TK and exam system.