Maybe. Although there is a reason there's a difference. Different encodings support different data structures. Form data is an encoding that supports multiple keys of the same value, whereas json is an encoding that doesn't.
As it happens for JSON data, request.DATA may not even be a dict at all, it could equally well be a list, boolean or any of the other json primitives.
It's possible we could specifically handle the case where the top level obj is a dict, and use a queryset there, but in general I'd say that the right approach is to not depend on request.DATA not necessarily returning a QueryDict unless you're only using the form parsers.