I guess without the firmware fixes and possible case constraints or high ambient temperature then things can get hot. Benchmarks for various firmwares showed the original firmware hitting 70C very quickly. If you are pushing the Pi to its limits it will get hot. I may mount a full size heatsink, exposed to the outside of my case with fins running vertically, like a heatsink on a power amp.
Before I could unbox my RPi4 I had to do the washing up and this potato masher reminded me of something…