All of these assume your background metric is Euclidean. If your background 2D metric is a projection of a warped 3D space, you can make π as big as you want by tugging on the centre of the circle.
Any metric that "pulls on the origin" compared to Euclidean distance will have to do the mapping in a continuous way. This will basically result in both the radius and circumference being expanded in that metric.
Matter of fact, I linked an article that proves that for _all_ metrics, the value of π is always between 3 and 4 (inclusive). Unfortunately the article might have gotten the hug of death so here is an alternative link: https://www.researchgate.net/publication/353330827_Extremal_...