MegaMan also had a comic during 2011(while Smash 4 was in full development). Castlevania is quite alive via the animation and the Pachinko games. Neither franchise were "irrelevant" when they first got content in reality. They were in active use during that time. Just because the current usage of the franchise wasn't liked by some fans doesn't mean they were irrelevant regardless. We don't have any legitimate examples of an inactive 3rd party franchise when it was added among the playable characters(an important distinction. Some of the MIi costumes were from inactive franchises, which while it kind of makes the character playable, it's not the same thing. Ryu, Pac-Man, MegaMan, Bayonetta, etc. were all full playable characters and all from in-use franchises during that time). "Just having games" is not how a franchise works. A huge amount of franchises in Smash alone are more than games now. Manga, Comics, Cartoons, Anime, Movies, all kind of Toys, and so on. That's a huge part of what keeps them active. MegaMan definitely had some moments of inactivity, it just wasn't during Smash 4's development cycle. See down below why toting the whole relevancy as an argument for or against Banjo & Kazooie is meaningless, though.
Every 3rd party when added was an active franchise in some way during their first addition(that is, added during development. Veteran 3rd parties don't count for what I'm referring to). But this doesn't really matter as relevancy is only an official factor for 1st(and 2nd) party franchises at best, as well as can affect 1st/2nd party playable representation(outside of Mii costumes). And that's ignoring Retros, of course. Or surprise characters. Though incidentally, the surprise characters who weren't Retros were also fully active during that time with their franchise. There's little point in bringing it up for B&K, however. There's no example of a 3rd party character being made straight playable(during development time) while their franchise was completely inactive. There's also no reason to believe it was ever a requirement either, despite the pattern implying so. Not when Sakurai's statements don't suggest relevancy to mean much beyond very specific situations(which all are not 3rd party ones). If he did somehow care about a franchise having some activity, B&K could still get in anyway. Things like Rare Replay absolutely count. The franchise is being used, even if it's not new games or any kind of new forms of media/works. Simply re-releases is enough alone. Sure, Pac-Man was active outside of that(not just Ghostly Adventures, but the design people associate with it was used for other games before the cartoon came along, but it was still getting consistent re-releases of the original arcade game, keeping it consistently active for people to see). Though I won't say constant re-releases is necessarily a case for relevancy either, but it seems like it's keeping the franchise going anyway.