The real question is can active stock picking beat the S&P 500 index, after fees?
Fidelity has an actively managed US Large Cap Equity strategy that beat the S&P 500 index over the past 5 years ending 4/30/2024. Below is the link.
https://digital.fidelity.com/prgw/digital/msw/details/USLargeCapActive?taxManaged=false
If they can continue this performance for another 5 years it will be a remarkable accomplishment. It may have performed better because it only has 200 positions vs 500. Does that mean less is better? The DJIA 30 stock ETF (DIA) returned 9.45% over the past 5 years, the S&P 500 stock ETF (SPY) returned 13.09% annually for the past 5 years, and the Russell 1000 stock ETF (IWB) returned 12.72%. (All ETF returns are from Yahoo finance and are after fees. The Fidelity returns note the S&P 500 index to have a return of 13.19% while their strategy returned 13.61% after fees