Any higher-end card will increase case temps.
OK, you're pulling 50-150w for the CPU
Now you can be pulling another 50-100w from the video card. Probably 50w, or more, more than the 9600XT.
That power must be dissipated somewhere. With reference coolers, it will be exhausted into the case. The hot air then goes towards the CPU and PSU, and is exhausted. The more power, the hotter it will be. Arctic Cooling VGA Silencers offer a good solution (though some people have had problems seating them).
A 9600XT can run passively in a crappy case all day long. Only Gigabyte believes a 6800GT can run passively at all 🙂.