I shot 2 does in the head with my 30-06. I did it once because I was near posted land and didn't want the deer to cross over. The other one was, I guess, just to be cute. I believe the first one was justifyable. The second one was not.
The risk of wounding a deer and having them starve to death is too high in my opinion. I personally know of 2 deer who were shot in the head and not recovered. It's a sad situation.
With a bow-never!