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Android cannot know who is scrolling but it does know it is connected to a car. The obvious solution is to disconnect it from the car in order to scroll through the app. It's completely insane to use a phone while driving and that's the origin of the message. Attempting to subvert that mechanism is asking for trouble.
Just because the phone is connected to the car doesn't mean that the driver of said car is using the phone, or that the phone even belongs to the person driving.
It is Android's job to provide music and entertainment to my car's head unit. It is my job to drive safely. It is NOT the job of Android to make sure I'm driving safely. Why in the hell should my passenger have to sit through repeated "safety breaks" while they try to scroll down to play a new song?
Indeed just issuing a warning at connection or so "keep in mind to drive safely and keep an eye on the road" would be more appropriate IMHO. There is the same kind of restrictions with Waze, you cannot access the keyboard when driving and are forced to use the speech recognition which is often difficult (especially in foreign countries where street names are in foreign language).