Not necessarily. I think it was intended that the higher horsepower cars (300 and 350hp), especially those with manual transmissions, were to get 12 bolts, but I've personally owned a '65 L79 (350hp/327ci) car that had a factory installed 10-bolt posi. There was a strike at the axle plant in late 1964 which may have caused some supply issues at that point in the model year. I do know the car I owned was all original (paper work, knew both previous owners, the salesman who sold it, folks at the dealership who sold it, etc.) but maybe it was a total aboration or a factory mistake or caused by axle supply problems.
The L79 car I own now has all tinted glass (all correctly dated as well) yet the cowl tag says it should have only a tinted windshield so it's clear that mistakes were made. (This one has a factory 12-bolt by the way, wish I'd kept that 10-bolt posi that came out of the other L79 car though.)