You only need a torque wrench if you care about how tight the retaining bolt is snugged down.
You only care if the retaining nut is snugged down if you want the axle and wheel (and the associated tire) to remain on the bike during operation.
Do you want the tire/wheel combo to stay on the bike? Well that come down to how much you care about the operator's health, safety and general welfare.
I guess that makes it a judgment call?
In other words use a torque wrench (please).
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Truax
2007 Bonneville: bar end mirrors, Renntec Engine Guard, MCR Luggage Brackets & Seat Rack, Cortech Saddlebags, GenMar Handlebar Risers, National Cycle Windshield, Hutchinson Custom Brackets, Ikon shocks, Hagon progressive fork springs.
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