It is possible, but unlikely. Fires will burn and spread to any place as long as there is heat, oxygen, and fuel. The fuel in the forest would be the bark and wood of the trees and of course the heat from the fire and the moderate temperatures of forests anyway would keep the fires burning and spreading to the entire forest. If somehow the fire stifled out the oxygen below it, it would not spread below and only continue to burn the tops of the tress where all of the oxygen is; however, this is very unlikely.
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