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Check this note in metalink:
Doc ID: 96170.1
Apparently that note says that yes, you need to explicitly kill them.
Based on the documentation:
[SNIPED - Session inactive, waiting on the client|http://download.oracle.com/docs/cd/B19306_01/server.102/b14237/dynviews_2088.htm#REFRN30223]
So I'll expect they count as sessions and you could have an error on the maximum number of sessions opened.