I'm pretty sure strcpy et al pre-date the introduction of varargs. Besides, there's no reason the format string couldn't be the last argument of printf, except the specific technical detail that C requires at least one mandatory argument in any variadic function (the variable's address is used to locate the optional arguments in the stack.)
On a machine's runtime stack, there is no indication of how many parameters were passed to the function (at least on x86). C functions must use one of the mandatory arguments to determine how many arguments were pushed on the stack. In the case of the printf-family of functions, it's the number of format specifiers, e.g., "%d".
