A client simply isn't enough. If I needed to collect lists manually, I have better "devices" (see: applications) to do so.
What nested NIP-51 lists would allow for is enabling entire protocol to have organized, managed lists.
Let's say I build a client for "managing friend lists," well, I've really just built a "list managing client."
This is basically a hindrance for any application that wishes to have modular list organization.
Nostr needs to manage lists natively.