to_lower is in the std namespace but is actually just part of the C89 standard, meaning it predates both UTF8 and UTF16. Is the alternative that it should be made unusable, and more existing code broken? A modern user has to include one of the c-prefix headers to use it, already hinting to them that 'here be dragons'.
But there are always dragons. It's strings. The mere assumption that they can be transformed int-by-int, irrespective of encoding, is wrong. As is the assumption that a sensible transformation to lower case without error handling exists.
> Is the alternative that it should be made unusable, and more existing code broken?
It should be marked [[deprecated]], yes. There is no good reason to use std::tolower/toupper anywhere - they can neither do unicode properly nor are they anywhere close to efficient for ASCII. And their behavior depends on the process-global locale.
But there are always dragons. It's strings. The mere assumption that they can be transformed int-by-int, irrespective of encoding, is wrong. As is the assumption that a sensible transformation to lower case without error handling exists.