There are many practical reasons for going bottomless.
The sun: trying to avoid a sunburnt back might cause someone to throw on a t-shirt or t-top.
Chilly weather: same as the above.
Heavy breasts: my ex was heavy breasted. Standing or walking around might cause them to hurt; so she might turn her sarong into a makeshift bra and walk around bottomless at the resort. I've seen endowed women at nude beaches keep on their bikini top for the same reason.
Less common practical reasons: I was saw a woman wading in the pond at the resort. She was wearing a sarong; I assumed she was shy. When she got in deep enough she pulled up her sarong and tied it around her waist. I guess she either wasn't that shy; or she was more concerned about getting her sarong wet than being bottomless! Another time I saw a woman enter the nude beach wearing a very tight short dress; and the moment she hit the sand she pulled her dress up to her waist (no underwear) until she got to her spot. In her case I think she just wanted to walk freely.
Some nudists are against the bottomless look because they feel it brings too much attention to the genitals. I guess in a way it does when that's the only piece of nudity you see on a person. But generally the women who go bottomless would go nude if it wasn't for special circumstances.
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