It also needs to have the same swing as the upper hinge or it will bind.
When I do the hinges I will level them out in the closed position and check to make sure they are the same levelness, i'll even use a angle meter, then put them in the open position and do the same thing. if this is not perfect you will get premature bushing wear and/or binding.
This is why you see so many doors drop down a little or up when open.. this is to keep the 2 hinges parallel all the way through the swing. sometimes you can only do so much..
This is also why I buy the suicide doors hinge kit when I do them.. that way I know the bushings and everything are going to be mounted on the same plane on each hinge.. that way when I measure the angle of the hinges, I know i can count on the hinge bushings being on the same angle to the hinge on each hinge. Each hinge is put in the same jig before welding..
Normally I put the hinge assembly together before cutting the hole in the pillar also.. I can make the hinges work on the same plane before installing..
then I can set it up to the piller and try got get it as level as possible without getting into the skin..