"man mke2fs" (dated "July 2008" in the man page headers) describes the
'-t' option as:

       -t fs-type
              Specify the filesystem (i.e., ext2, ext3, ext4, etc., is  to be
              created.   If  this  option  is not specified mke2fs will pick a
              default either how the command was run (if it was  run  using a
              name of the form mkfs.ext2, mkfs.ext3, etc.) or via a default as
              defined by the /etc/mke2fs.conf(5) file.

At least to me the wording "specify the filesystem" means precise control over 
the
filesystem type to be created and not the "minimum level" which may be get
automatically (and silently) upgraded if additional features requested by '-O' 
(or -T, I suppose)
need a higher ext2 variant.

The very latest upstream man page may have an updated description of '-t' but 
if not,
I would suggest something along these lines:

 -t fs-type
    Select the base set of filesystem options (-O, -T) according to the 
definitions
    in /etc/mke2fs.conf(5) file.  There are typical option sets (i.e. ext2, 
ext3, ext4, etc.)
    available.  Additional options (-O, -T) can be specified and they will be 
merged
    to the base set of options according to rules described in mke2fs.conf(5).
    The actual filesystem type that will be created is deduced from the final
    set of merged filesystem options.

    If  this  option  is not specified mke2fs will pick a
    default either how the command was run (if it was  run  using a
    name of the form mkfs.ext2, mkfs.ext3, etc.) or via a default as
    defined by the /etc/mke2fs.conf(5) file.

Or something similar.  The main point to me would be that the man page should
make it clear that you may get something else than ext3 even though if you
specify '-t ext3'.

-- 
mke2fs creates ext4 ignoring '-t ext3' if ext4 features specified
https://bugs.launchpad.net/bugs/276694
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