OS upgrades (both major and minor ones) have been known to change heat management routines, so it's possible. Could be a combination of a different fan scheme and something that's hitting the processor harder after the upgrade, either of which could make the 'book feel hotter.
My only significant experience with this was upgrading a 12" PowerBook from 10.2 to 10.4, and it actually ran DRASTICALLY cooler after the upgrade--the fans ran much more frequently.