I rather doubt that. I don't see anything in the manual or other documentation that REQUIRES you to be on the current firmware. Think about it - you are languidly floating on your boat in a South Pacific paradise, disconnected from the Internet, cell phones and McDonalds, taking beautiful pictures of the surrounding terrain. DJI nefariously pushes out a new firmware version. Let's say, for the purposes of this argument, that it was version 1.6 which presumably dealt with cold weather battery behavior.
You're flying along, the little stress crack that you did not notice before becomes a big stress crack and the bird unceremoniously plummets to the ground. Stress cracks are a known fault and DJI has been fixing this issue under warranty.
So, now DJI can hide behind 'the firmware wasn't current'? I really don't think so.