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The Release Notes for Studio 12.3
lists the minimum OS version as "Solaris 10 10/08", which is S10u6, not S10u10. So you are safe in using S10u9. (Sometimes documentation refers to the date of the update and sometimes to the update number, which I agree can be confusing.)
The basic runtime compatibility rule has been that you can run on a newer OS version than where you built, not necessarily on an older OS version. The problem is that new OS versions introduce new interfaces, and a program might intentionally or unintentionally depend on an interface that does not exist in an older Solaris version. In that case, the application would not work on the older OS.
Historically, updates to Solaris were only bug fixes. But Solaris 10 has been out so long that some updates introduced new features and new interfaces.
A safe rule is to build on the oldest OS version that you intend to allow clients to use. For Solaris 10, it is safest to extend that rule to the oldest update that you intend to allow clients to use.