From a reading of the spec it seems that a GeometryCollection is a Geometry and can contain geometry objects? But I want to be sure that this is really allowed before I file a bug report.
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Update: nested collections are specifically NOT RECOMMENDED in the latest GeoJSON specification.
To maximize interoperability implementations SHOULD avoid nested geometry collections. Furthermore, geometry collections composed of a single part or a number of parts of a single type SHOULD be avoided when that single part or a single object of multi-part type (MultiPoint, MultiLineString, or MultiPolygon) could be used instead.
https://datatracker.ietf.org/doc/html/draft-ietf-geojson-03#section-3.1.8
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Yes, it should be allowed. And I have tested it on OpenLayers at least, you can create a feature whose geometry is a GeometryCollection which contains another GeometryCollection by reading a geojson string (using OpenLayers.Format.GeoJSON object).
mfdev
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