In good lighting conditions, few cameras are capable of besting the 13 megapixel Galaxy S4. In low light however, the S4 stumbles more than it should.
The HTC One and its 4 megapixel UltraPixel sensor excel in low light, and though it's not the absolute best camera in natural life, it is certainly good enough.
Since most people don't really want to take the time to fiddle with limited camera phone settings, it's important to be able to fire off clear photos in dim settings.