Unclear what you are getting at here. I expect you are right about that in respect of a cell phone. A receive-only cell phone would I suggest be completely useless (not even usable as a radio receiver, due to the security protocols used by mobile phone communication). However if you are responding to …
that is a good point that @matt2 makes. In theory governments / telcos could be doing that and that would make it quite hard to do the kind of fakery that I was imagining. Are governments / telcos actually doing that? Who can say?
However the receive-only devices in that case are effectively receive-only base stations, not receive-only cell phones.