If you mean "the skill of actually programming", then no, that's absurd.
Would you tell someone they can be a "top sports player", if they have a life outside of playing that sport? A world class chef who doesn't give themselves over to cooking? Anything that actually involves skill? A musician? A painter?
Because if that's the case, then no. I'm sorry, you're battling against reality. There's a little thing called opportunity cost, and whether we like it or not, how far you can walk down a particular skill-set is DIRECTLY RELATED to how much time and work you put into it.
What's perhaps a better message is both: a) employers, you aren't actually hiring superstar coders, and if you want to, you'll either pay for it, or better make your workplace the kind that attracts them. And b) developers, you're probably not going to be the best in the world at what you're doing...and you know what...at least from a personal psychology perspective...that's ok.
Now from an economic perspective, if you're worried that you're not going to be able to hold down a well paying job because they demand too much...well, there you've either got a problem with reality (skills take a long time and hard work an practice to build), or the economic system, cause maybe there's a lot of desperate people out there who can code for peanuts and will take shitty conditions...and capital is being amassed into fewer and fewer hands and increasingly has no interest in paying to upskill you or whether you can have a reasonable life outside of work. :P
Not sure about painters and musicians, but professional sportsmen burn pretty rapidly, both physically and mentally. You can be the best coder in the world at 25-30-35, but if you devote your time to coding and coding alone you will eventually burn out. It's not a matter of if it's only a matter of when.
I'd rather be an average-to-mediocre coder who codes well into his 40s and 50s then having to deal with depression and end-of-world scenarios brought about by burn out and the feeling that it's no use in you writing code.
I've been living at a tennis academy for the past two months, and I've seen firsthand what's expected of the top players. To keep up the necessary training intensity, regular recovery periods away from tennis are built into their schedule.
In other words, having a life outside the sport is not only possible, but necessary for top performance.
I view there being two issues here as separate phenomenon.
You probably won't be a top coder if you're not willing to put more effort in than is available at work or during an 8 hour day: if not just because the modern workplace isn't as a whole very conducive to properly upskilling its workforce, and because there's a whole lot of people out there who are willing to put in more time, money, and effort than just those provided by full time jobs to study/implement their skills.
To be honest, I don't even think most companies even have a place for, or even necessarily WANT top coders.
On the other hand, there's this issue of should companies have an expectation that you're putting in extra work/hours to get a job/get ahead. And that's a big complex issue there that I think has to do more with society/culture/economics than whether you're a top/good coder at all.
My self and my (now) wife, as a living example, generally try to live close to work. We've rented for 10 years, moved 5 times now, and lived in a 1 bedroom apartment together for 5 of those and try to live without a car. Sacrifices many of our friends simply do not contemplate as "possible" On top of that, I've done my best to learn as much as I can on work's time.
All other things being equal, will the person who makes life choices, be it living out in the burbs, watching TV, having children earlier, partying or drinking, etc etc, be top developers, relative to me/us?
No. In fact, I can squeeze in hobby/health that takes place with the time/money (albeit not one that uses space) savings afforded by these sacrifices and still compete with them, and the synergies afforded will still probably put me ahead.
Now there are some people, perhaps those with rich parents who gave them access to computers earlier than me, buying them big spatious houses adjacent to where they work, with all the right connections and contacts who can probably out-compete...and as hard as this is to admit, probably out-ability me, but that's life, and that's reality.
But the other reality, in addition, is developer wages and conditions, ESPECIALLY in the US, are rediculously/obscenely high at the moment, and I'm well aware that there are people below me in terms of living conditions who are probably even hungrier for those positions than myself.
Could you be a "top developer" without putting in the extra hours that the top developers do? Either because you love it or because you're making a strategic decision to do so?
All other things being equal, I don't think so.
And if you DO, i think its probably because its due to being in a social structure that pretty much thumbs its nose at even trying to live up to the ideal of a meritocracy...