Well you can disagree with me if you want to...
But you will also have to disagree with two very respected Smith & Wesson researchers - Robert J. Neal and Roy G Jinks, who before retiring was Smith & Wesson's company historian.
In their book,
Smith & Wesson, 1857-1945 they say:
.38 Hand Ejector, Military & Police Model 1905 Fourth Change.
Cylinders were heat treated beginning in 1919 at serial number 316,648.
Their source for this came from a notebook kept at the factory by an engineer in which he logged various changes and other data of interest between 1919 and about 1951. He noted the following:
May 7, 1919 Order to treat all .32 Hand Ejector Winchester cylinders by J.H. Wesson.
Shortly after the same was done with .38 Special cylinders at the above noted serial number.
Jim Supica and Richard Nahas (Also well recognized authorities) in their book
Standard Catalog of Smith & Wesson say concerning the .38 Military & Police; 1905 Hand Ejector:
... heat treated cylinders begain at serial number 316648.
I could go on, there is more...
When the first M&P hand ejector came out in 1899 with the 38 special the round they reported using was a 158 gr running at 870 fps. Now this was black powder but it appears evident that the early M&P 38 specials could handle want is called todays "+P" round.
As you correctly note, "Now this was with black powder" and also out of a 6 1/2" barrel. Black powder is a much slower burning propellent then smokeless and while the pressure may (or may not) be higher, spreads it over a much flatter curve, Thus a smokeless charge, that is burning faster, causes higher stress in the chamber. Now as you noted, some Plus-P ammunition is on the wimpy side, and "plus only in name" However the problem is,
not all Plus-P ammunition meets this description! Consider the previously mentioned Buffalo Bore products, even you say.
Maybe exception would be Buffalo Bores +P round.
Darn right!, which is the reason I'm careful in what I say.
Ya' can't say on one hand, "
Any Smith and Wesson chambered in .38 Special," and then, "Maybe exception would be Buffalo Bores +P round."