The basics of a hostile takeover are basically "buy or control enough stock to replace the board". This doesn't necessarily require you to buy 50% of the voting stock, just enough to control policy.
Would they? I don't know, but from their proposal so far I'd say the answer was "no". The original proposal was financing the purchase with Comcast stock (Disney shareholders would get Comcast stock), and a hostile takeover would take cash. They've also indicated they're not willing to up their offer, but that could just be part of their game right now.