Do I really need to encode ‘&’ as ‘&’?

I’m using an ‘&‘ symbol with HTML5 and UTF-8 in my site’s <title>. Google shows the ampersand fine on its SERPs, as do all the browsers in their titles.

http://validator.w3.org is giving me this:

& did not start a character reference. (& probably should have been escaped as &amp;.)

Do I really need to do &amp;?

I’m not fussed about my pages validating for the sake of validating, but I’m curious to hear people’s opinions on this and if it’s important and why.

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