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OK, it would seem that the outter scroll is going to show up whenever the Detail Pane is not fully exposed, i.e. full height.
In the example I mentioned (and not fully explained): two panes are open, Data Explorer on the left, Detail Pane on the right, and View | Status Bar is selected. By revealing the Status Bar this limits the Detail Pane from becoming full height, thus the outter scroll bar is revealed.
The same is true for the screen shot you supplied, by positioning the Child Pane below the Detail Pane, the height of the Detail Pane has been restricted and the scroll bar is revealed.
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