Under OS X 10.6, in the Security panel of System Preferences there's an option to "Require a password to unlock each System Preferences pane". At least if that's set, there's no way for software to add a login item without a password.
I'm afraid that's not correct. Locking the Accounts preference pane doesn't prevent a user from using it to edit his own login items. Even if it did, he -- or a rogue process running with his privileges -- could edit the corresponding property list directly, without going through the preference pane. The process could also add a user LaunchAgent, which wouldn't appear in any preference pane, and, if the file were invisible, wouldn't appear in the Finder either.
If you looked at the permissions settings of the things in the /Applications and /Library folders you'd notice that many of them are owned by "system".
/Applications is still writable by the admin group, and third-party applications installed by dragging are owned by UID 501. Many items in /Library are group-writable, including Internet Plug-Ins. I had to look at my installer receipts to find this out, because I've been overriding the default permissions for years.