I don't know there is a for sure answer. I know that bears are tough and the fat and hair can make things complex in a hurry. I have killed 4 bears. 2 with a rifle and 2 with a bow (and I lost a 3rd with a bow; still don't know how that happened). Both with a rifle were close and DRT. Both with a bow were near perfect shots and they both went about 50-60 yds. One had a good blood trail the other one only left a drop of blood and some hair at the shot sight.
With a rifle, breaking the shoulder makes a lot of sense to me. Bullet construction has come a very long way in the last few years and can make a substantial difference. That is not to say that shot placement is not even more important but it all factors in. I guess my thoughts are a larger caliber rifle with a premium bullet are not sure fire but certainly would help.