Support for removing destinations with active subscribers has been added for 3.2.4
The subscriptions are closed before the destination is removed, instead
of throwing the exception you show.
We are having this same problem and it doesn't look like 3.2.4 (with the fix) is going to be relased. (I only see 4.0 beta.)
In any case it is often a serious decision to introduce instability by changing a product's release platform.
Does anyone know a workaround to clear out or close the existing subscribers on 3.2.3?
To work around this, we kept a reference to the single TopicSubscriber and TopicSession used in conjunction with our topic and called close before calling destroy().