It really has more to do with management. Ten frame hives and top bar hives will swarm if they are healthy filling up the space and you are not monitoring their status to mitigate swarming. The strategies you use will differ between the two hives operationally, but not conceptually.
This podcast / forum is very informative about top bar hive operations:
by slouden » Sat Oct 12, 2013 9:46 pm