from 28 to 31 spline axles. When is it necessary?

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A 28 and 31 spline diff cost about the same and sometimes literally the same. Basically if you go 5 lug 31's are a better choice, since you are buying axles anyway.

If you aren't using a drag radial or slick, you'd probably never break a 28. But it could happen.
 
there was a car around here that was running stock axles running high 5 seconds (1/8 mile)

That is an accident waiting to happen, you'd think a guy savvy enough to get his car that fast would be smart enough to use better axles.
The axle doesn't have to break before the car starts moving.
 
I broke my stock axles with a pretty much stock engine. 220hp 284tq
Using M/T Radials on a track that everyone said never hooked.

Id say its nessessary if you plan on launching it decently at the track.
But some get lucky. Id upgrade just to put a better diff in the car.
 
personally if you are sticking with 4 lugs then just buy a 28 spline moser or strange axle. Why add the cost of getting a 31 spline carrier perhaps the cost of rebuilding it and the cost of re setting up your gears. Easier to buy a set of high quality aftermarket axles. 28 spline. Provided you are not a 9 second or quicker car.