No, shoot-through current is when both are conducting
(within a single gate).
Short circuit current is when the output is shorted to
something. The most probable being ground, although
it is possible to find the supply or some other output
(in which specific case, NMOS of one and PMOS of
the other is your both-on condition).
Output buffer specs often include short circuit
current. Internal gates, never have I seen this cared
about (if it's shorted, it's inked).