The reason 10.1 came on a seperate CD was because it was so different than the original, that downloading it would be impractical even for broadband users. You basically needed the CD to install.
Considering Jaguar has so many internal changes to still like the kernel, I'd expect it to come on a CD. It shouldn't cost you anything, just stop by your apple Store and they hand it to you. Or you can mail in a form and get it through the mail.
For major upgrades, it's not too practical to install it via software update. they could go OS 9-style and basically run the updater which reboots to it, so it can make internal changes without interfering with the system running. I guess it all depends if it's small enough of a file or not.
but i wouldn't be surprised to see it come on CD. It is a major update, so I wouldn't be shocked.
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