It's not strictly an error if you're sure about what you're doing. SDK 9 is required only on the native side, only to build the special library for the Xperia PLAY touchpad. If you were to exclude that library from the build you could build everything for SDK 5. I.e. we're not using any APIs above 5 anywhere else in the native code. If SDL 2 truly requires API 10 then it just wouldn't build, plain and simple.
I'm not sure why the SDL2 readme says that API 10 is needed, but the Java Android code provided with SDL 2 is just a hello world example and we're not using it. We are using some higher APIs in the Java code but the version is always run-time tested before executing any of that code.
Edit: Also, only in the latest NDK (8e) does ndk-build even throw a warning about API mismatch between native and java side.
Edit2: Ok, I tried my own suggestion and you're right, SDL 2 does require platform-9 for EGL headers (though it seems only for some macro constants).
As Paul said, let's see if anyone with a pre-2.3.3 device can run it before throwing in the towel.