I think "must" might be too strong of a word. For example, on an I6, there is no intake to remove. There is no way to visually inspect the lifters while the rockers are installed.
Basically, pre-load is the tension on the plunger in the lifter so that it reacts on a timely basis when the rocker isactuated by the push rod, which is driven by the lifter's ride on the cam lobe. Think of it as taking out the slack.
Basically, on adjustable rockers, instructions say to turn out the adjustment screw before installing so that when the rockers are installed, there is no tension at all against any of the push rods. This is a zero pre-load condition. You adjust the rocker until there is no gap between the rocker tip and the push rod, then turn the adjustment screw between 1/4 and 1 1/4 turn, depending on the manufacturer of the rocker. This sets the pre-load. This adjustment is made when the valve is fully closed, which is a condition found when the lifter is at the lowest point of the cam lobe.
If factory style rockers, which are non-adjustable on a 289/302 hydraulic lifter cam, proper torque on the mounting bolts plus correct length of the push rod sets the pre-load. In some applications, the factory manual states that it is unneccessary to set the preload. When it becomes necessary to do this on non-adjustable rockers (such as when the head gasket is changed to a different thickness or the deck of the block surfaced or head milled) it is done by changing to pushrods that are something like .060 over or under the factory length.
I've always adjusted my rockers with both the head and intake installed. True, I can see advantages to adjusting rockers with the intake off (on a V8). You can visually inspect that the lifter is at the lowest point of the cam when setting the adjustment. You can also make sure that you are not over-tightening the adjustment screw and starting to depress the plunger in the lifter. Thus, while this approach might be considered a best practice, it is not a necessity. Otherwise, one would never be able to properly set valve lash for I6 engines. (The 170 came stock with adjustable rockers, the 200 and 250 came with non-adjustable shaft mounted rockers. I6 engine builders will swap the 170 rockers onto a milled 200 or 250 head so as to adjust the rockers to compensate for the amount of material milled off the head and retain correct valve train geometry.)
good luck