Assuming that the fstream object is local to the function, I would tend to argue against this. People need to become accustomed to letting RAII do its job, and closing an fstream object falls under that heading. Extra code that doesn't accomplish something useful is almost always a poor idea.
Edit:Edit: Lest I be misunderstood, I would argue against this, not only for this specific case, but in general. It's not merely useless, but tends to obscure what's needed, and (worst of all) is essentially impossible to enforce in any case -- people who think only in terms of the "normal" exit from the function really need to stop and realize that the minute they added exception handling to C++, the rules changed in a fundamental way. You need to think in terms of RAII (or something similar) that ensures cleanup on exit from scope -- and explicitly closing files, releasing memory, etc., does not qualify.