ESD Protection for Ground?
It could, if the current was extremely high or the layout was bad. 

I saw a device (a data drive plugged into a computer) some years ago, and it was being used on a circuit connected to the mains- risky at the best of times but it was nominally okay. Due to sloppiness and rushing, the ground lead wire on the drive (a braided wire with a ring terminal, flapping around) accidentally touched the "hot" which vaporized the trace to wall plug ground but there was still a capacitor from the now 120VAC node to +5V, which blew out every single chip in the drive and the computer. It also caused a potentially dangerous voltage to appear where it shouldn't. Ideally that would have just blown a circuit breaker or tripped a GFCI.

Less catastrophically if there is a path to ground from an external terminal that is not direct, but passes through other circuitry, glitches or even damage are possible from ESD.  

Beware of current paths that may exist through your design where current is not limited in some way.