I disagree. I have run both 33/35" tires on few jeeps I've owned with no problems. and no sawzall! and the jeep was all stock. one was a 1980 cj7 which I ran 33x12.5x15"bfg at's. And the other was a 1982 cj5 which I ran 35x12.5x15 bfg mt's and then 36" or q78 buckshot mt's with no problems, and no lift. The only time they rubbed was at full stuff(which most jeeps do unless you have it set right)! But I can say that I have owned other jeeps that would not fit 31" tires stock. like my 1986 cj7 would not fit anything bigger then 31" bfg at's. and also a 93 yj I owned for a short time was almost a low rider. so I think it depends on the jeep.
Also I noticed that there is two pic's above. which one is more current?