Yes.
Are you talking about s_root field of struct super_block ? Then it ideally should be of root. I checked some file systems implementation of fill_super().
fill_super() is the method that sets the s_root field of super_block. I found all of those file systems *rightly* calling d_make_root() API which actually makes root dentry with name '/'.
So the question you should ask yourself is which file systems code are you referring too, how is it setting the s_root field of super_block in their fill_super method. You will get your answer. Unless some file system is doing some very weird thing, I believe it would be calling d_make_root() VFS API only which does the task for you.