No, you can only run the same-bitness for Xenified guests.
Xen 3.x supports unmodified guests at any level of bitness (up to whatever Xen
itself is, you obviously can't run a 64-bit unmodified guest on top of a 32-bit
Xen).
But for Xenified guests, the Xen-build and the Guest-OS
must be the same - this is because it's actually quite complicated to
translate the different page-table levels and map the memory such
that the guest can access it, etc [not exactly rocket science, of course,
but it does make life more difficult for the hypervisor].
It has been discussed to make a shim-layer that translates
the Xen-calling interface.
Is there any particular reason you feel that you must run a
32-bit guest-OS. Almost all applications will work just fine in a 64-bit guest.
Of course, there are some exceptions... If so, then you do need to move to
32-bit host-OS as well as guest-OS, yes.