Right, I tried it without the Bursa Wolf parameters, and indeed the results are 
near identical:

epsg-wkt:

278204.21690185793, 187591.0788272909

PostGIS: 

278204.250150917 187591.006280736

As opposed to epsg-hsql:

278291.1032887026, 187619.97719849477

So your hypothesis is correct. Digging into the PROJ.4 docs, it says: "Support 
has also been added for 3 and 7 parameter datum shifts" but various mailing 
list posts imply that PostGIS maybe doesn't always take advantage, eg: "The 
most common reason for failure to populate a datum shift is that there are more 
than one available going to WGS84 for a given datum. Since I can't know which 
is best, I just ignore them all." - 
http://postgis.refractions.net/pipermail/postgis-users/2005-October/009678.html).
 

As a novice, I am struggling to understand the details, so suffice to say that 
GeoTools is accurate and (my Windows installation of) PostGIS/PROJ.4 is not!

Thanks again.

Simon


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