see Writing to a read only session in MVC 3+
That post claims the behavior is inconsistent.
I am definitely able to write to Session in Controllers using ReadOnly.
I Would treat it like this:
I realize this is counter to http://msdn.microsoft.com/en-us/library/system.web.sessionstate.sessionstatebehavior.aspx
Read-only session state is enabled for the request. This means that session state cannot be updated.
but it seems you in fact can update session state under some scenarios.