My understanding of this....
Considering a theoretical 2 pole amplifier. With a theoretical 2 pole amplifier it shouldn't be possible to actually reach the loop gain=1, loop phase=-360 degrees condition necessary for instability where the closed loop gain theoretically goes to infinity, obviously limited by the power rails.
But for low phase margins there will be some peaking in the closed loop response at the top end of the closed loop bandwidth. If the phase margin is low enough then this closed loop response peaking can be large enough to result in a small amplitude high frequency oscillation riding on the signal waveform or indeed as a small amplitude high frequency oscillation even if there is no input signal (apart from noise). As the phase margin approaches zero degrees the high end closed loop gain (peaking) becomes greater and even though it can't get to infinity, with only two poles, it can become large enough (close enough to the loop gain=1, loop phase = -360 condition) to theoretically be large enough that it will become limited by the power rails. I wouldn't actually class this as instability because the output isn't theoretically ever increasing but has a maximum limit although the power rails limit the amplitude to lower then its theoretical peak.