I don't doubt that it's theoretically possible all things being equal but the likelihood is very small with fipronil custard. In the tick example you cite there is a long term low level diminishing exposure to fipronil. So even when administered orally or by injection fipronil will persist for up to 21 days. Not only is there therefore constant exposure at high tick population levels to favour survivor reproduction, as the fipronil residues taper off they become sub lethal which further aids development of resistance in otherwise more susceptible individuals. Notwithstanding all of this, resistance in ticks is still relatively low.
The preening and trophallaxis behaviour of velutina queens is their archilles heel which is exploited by fipronil custard. Importantly, there's no passive exposure with the method to enhance the probability of resistance developing.