Look at it this way, A 1PH transformer with either a 240/120 or a 120/240 secondary providing power to a 1ph3w load requires secondary protection.
A 3ph transformer that supplies power to a 3ph4w load must have secondary protection.
A 1ph transformer that simply feeds a 1ph2w-load need only to have primary protection is the pri. OCPD is sized correctly according to art 450.
It is the same for a 3ph transformer, which simply feeds a 3ph3w load.
In both of these examples the secondary current is proportional to the primary current so a pri. OCPD can protect the secondary.
Not so with a 1ph-3w or a 3ph-4w secondary. Think of it this way, if it is possible for the secondary to provide power where there are unbalanced L-N unbalanced loads if primary only over current protection was provided it would not see the unbalanced load and would not provide adequate transformer overload protection.
