I've done them both ways and had same results from either. Just be sure if you use a block under your oil pan that it spans clear across the pan so it is supported by the vertical portion of the sides of the pan otherwise you can still put a pretty nasty dent in the bottom of the pan and worse case scenario push the pan up against the pickup tube inside.
If you have access to a lift I prefer to use an engine support fixture and support the engine from the topside, pull the motor mount bolt, raise the engine slightly and raise the Jeep up to gain access from underneath. Nothing in the way then.
Mike
I have pulled the tires off my jeep and lowered it to make it easier to support/work on.
I think that the big motor mount bolt on the driver side gets in the way of something, I seem to remember in my case that I am hosed either way, I seem to remember cursing my York OBA mount last time I messed with it.
I will let you know in a few months when I rebuild my ax15 and have to lower the engine to un-bolt the transmission. (boy how a tj with a body lift sounds like a great idea...)
All in all it is pretty straight forward in an XJ, of course I have only done it on an XJ with 6+ inches of lift so that might make it easier...
Nathan