And no one would ever say Bobby Heenan was the biggest heel of the 80's. They're going to say Savage, Andre, Roddy, Dibiase. Bobby isn't wrestling Hogan. There's a limit to what he can do.No, heel does not necessitate being a wrestler.
Bobby Heenan was one of the biggest heels of the 80's, he was retired and a manager.
Triple H was the wrestler of the heel faction, but that faction was led by Mcmahons and the top heel was Vince Mcmahon and Stephanie Mcmahon, later Kurt Angle gets added to list of top heels, Triple H was below them.