Daniel,
Short answer -
A short scale 12 fret could be built for heavy strumming.
Longer answer -
This question is a little subjective plus not enough is known.
What gage strings will be used? How short is the scale? What is the top material? Is it lightly built or over built or somewhere in between? How will it be tuned?
Most of what I see as heavy strumming is not appealing to me and generally players are hitting the strings too hard and playing beyond the capability of their instrument. It is much better to learn to play within the instrumenst capabilities. Good players learn how to do this.
Short answer - A short scale 12 fret could be built for heavy strumming.
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“Reason is itself a matter of faith. It is an act of faith to assert that our thoughts have any relation to reality at all.”
― G.K. Chesterton
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