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Confirming this still reproduces (2026-06-24, REST API v3 + github.com web UI), and adding a second half that isn't covered above: the loss can't be recovered through the documented API.

After the empty submit, I tried to restore the summary with the documented "Update a review" endpoint:

PUT /repos/{owner}/{repo}/pulls/{n}/reviews/{review_id}
{"body": "<the summary that was dropped>"}

It returns HTTP 422:

{"message":"Unprocessable Entity","errors":["Could not edit a review with a missing body."]}

So once a review is submitted with an empty body, that endpoint won't put a body back — and this 422 isn't documented as a restriction (the endpoint marks body as required but lists no empty-body or submitted-state condition). The summary then can't be restored via that endpoint; a workaround is to re-post the text as a separate PR comment. Inline comments on the same review are unaffected — only the top-level summary is lost.