Went on to become WWE Champion. So... Yeah, erm, they wouldn't.
Randy Orton saying that in WWE is completely different. That whole angle was already centered around Eddie's death. They had to get Randy some heel heat and saying he's in hell was obviously going to do that. They'd have obviously asked Vickie, Rey, Chavo etc before doing that who would have said that Eddie would've wanted the show to go on, them to use him to get heel heat on Orton etc. Besides, saying "Owen Hart is in hell" is nowhere near as bad as "I'm going to break Owen Hart's neck".
There's a difference what Randy did/said and what Kid Kash said. Orton said that during a heated feud centered around the big underdog Rey Mysterio winning the World title in tribute for his dead best friend Eddie Guerrero.
In films when things like rape happen, to actually get it published the film-maker generally has to have a "redemption" for that act. When Orton said that in the angle, the "redemption" was Rey Mysterio winning the World title for Eddie at the biggest stage of them all Wrestlemania.
Kid Kash for no reason aside from getting cheap heel heat from a Canadian crowd at a TNA house show claimed he wanted to break Owen Hart's neck. If it was part of an angle where they have Harry Smith come in or a random Canadian guy who then beats him, then at least there is some sort of pay-off to it. But to just use it to try and get Eric Bischoff's son over at a TNA house show? That's pathetic.