This is just a guess but bacteria have a cell wall that would be harder to penetrate than just a cellular membrane. Apparently the cell wall of plants doesn't require the same mechanism.
http://en.wikipedia.org/wiki/Bacteriopha...
"....Complex bacteriophages use a syringe-like motion to inject their genetic material into the cell. After making contact with the appropriate receptor, the tail fibers bring the base plate closer to the surface of the cell. Once attached completely, the tail contracts, possibly with the help of ATP present in the tail (Prescott, 1993), injecting genetic material through the bacterial membrane...."
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