I don't see the problem here. If they allowed anyone to submit a title without any backing from a trusted name or company, or without it already being a working title, the quality of the site would soon drop off a cliff.
The problem is that they've stated this (a production history) as the only condition of getting a listing during pre-production and then ignored the fact that the condition was in fact met.
IMDb told the team that if a movie is not set up with a production company with a history of theatrically released movies, getting it listed at the early stages of development would not be possible
The reasoning didn't have much to do with it being released via bitTorrent only.