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Not necessarily. The oil drain pan bolt gets a copper washer that can fail if tightened too much...its made to fail first so that you don't damage the pan. It probably cracked the washer and is leaking because of it. Heck maybe they reused the washer and it leaked because of that.
Could be a cracked pan if tightened WAY too much, but try replacing washer (which always comes with the oil filter kits) and re-torquing bolt first.
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