I know it happens from time to time. Last year while walking to my stand I was 3/4 of the way past 3 doe that were beddeed down 20 yards off the trail. I can think of other instancesd when I've walked past deer heading to my stand.
Now once I'm on stand the game changes. I do not think any slip by with in bow range once I'm situated on stand. I feel I'm just to vigilent to have that happen.