It depends on how you use Strength. As a measure of one's ability to utilize the physical power they have? No. As a measure of how much a person can lift, carry, etc.? Yes.
There are many D&D players who want a game based on real-world facts; yes, eventhough it is a fantasy game. The strongest woman in the world is not as strong as the stongest man. So, for an absolute "cap", yes, so the people who enjoy playing this way can.
This "cap" could be done by adjust max lift instead of STR score. It would be like the variant for using Encumbrance instead of a flat STR x15 rule.
Why do we need this cap when it's a fantasy game, and maybe my female character has a giant in her bloodline, or was blessed by faeries at birth, and can thus carry as much as a man?
Why do we need this cap when there's going to be at most four to six women in a party, and of them maybe only one or two are going to rely on Strength, and the GM controls
every single male NPC in the world and can make them as strong as they want them to be?
But OK, sure, it's "realistic" to assume that women aren't as physically strong as men. Sure. I recall a letter in an old Dragon Magazine from the 1e days--maybe in the letter column, maybe in the forum, can't remember--that went along the lines of: Women are healthier, hardier, can handle disease better, can
give birth, and live longer, so men should have a cap on Constitution. Women are more flexible than men, so men should have a cap on Dexterity. Women are better at problem solving and paying attention to small details, and everyone knows men do some
really dumb stuff, so men should have a cap on Intelligence and Wisdom. And, of course, women are just prettier than men, so men should have a cap on Charisma.
Some of the above is actually quite true. I can provide links, if you like.
So let's be realistic. Give men a small penalty to certain saving throws and ability checks. Nothing big. Just something that that amounts to a -2 or so on some rolls based on the fact that they decided their character didn't have a vagina. It uses real-world facts, so it's fair, right? If they don't want that penalty, they just have to play a woman.
Somehow, if the game tried to be "realistic" by limiting
men in this way, there would be an uproar, no matter
how "realistic" it is. Somehow "realism" is only OK if it supports your (generic your) bigoted beliefs.