You dont need to increment it as its at refcount 1 when its created, and isn't shared amongst multiple structures. But you do need to decrement if hv_store() fails as otherwise it won't be freed. And if DBI isnt doing that then I suspect its being a little naughty. :-)
AFAIK its really unlikely that hv_store fails so its probably ok. I just like to cover all my bases, especially as when im working on this stuff im usually patching core and somebody like hv or dave_the_m or Rafael or somebody like that will call me on it if I dont. :-)
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