I dunno. It must have something to do with cushioning the shot(?). The 1914 Winchester catalog shows the NPE 10 gauge Leader hull in 6 lengths, from 2-5/8" to 3-1/4". The same catalog has the loaded Leader 20 gauge with 2-1/2 drams of Bulk Smokeless and 7/8 ounce of shot in a 2-3/4" or 3" shell. The 28 gauge 'Repeater' has 2 drams of bulk and 5/8 ounce of shot in a 2-7/8" shell. These are certainly not heavy loads and could have been loaded in 2-1/2" hulls.
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GMC(SW)-USN, Retired
'Earnest Will'
'Desert Shield'
'Desert Storm'
'Southern Watch'
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