Take a closed stream-line, denote it as $\gamma$. By default the normalized tangent to $\gamma$, $\vec{e}_{\gamma}$, is proportional to the vector field $\vec{V}$ in question, $\vec{e}_\gamma \propto \vec{V}$. Now we can choose the orientation of the curve so that $\vec{e}_{\gamma}\cdot \vec{V} >0$. We realize that this implies that the circulation around the loop is necessarily positive:
$$\oint_\gamma \vec{V} \cdot \mathrm{d}\vec{\gamma} \equiv \oint_\gamma \vec{V} \cdot \vec{e}_{\gamma} \mathrm{d}s >0$$
We now apply Stokes' theorem to see that this implies that the curl of $\vec{V}$ must necessarily be non-zero in the region bound by the curve.
As for "rigor", there are a lot of unspoken assumptions here. For example, the vector field $\vec{V}$ should be smooth etc. Also, the curl of $\vec{V}$ can be non-zero in the sense of distributions for isolated vortices. However, once such "usual" assumptions are dealt with, the statement holds rather generally.
Indeed, the derivation above only shows that non-zero circulation is sufficient for non-zero curl. However, circulation is not necessary in the case of a non-zero curl, as the example of user lpz shows.
In some special cases, on the other hand, it is possible to show that non-zero curl implies circulation. For example, if your field is also divergence-free (such as the magnetic field $\vec{B}$ or the velocity $\vec{v}$ of incompressible fluids), and vanishing smoothly at the boundaries/infinity, there has to be at least a countably-infinite number of closed field lines. This is because in that case we can choose a potential so that the equations of the streamline can be cast into the form of a Hamiltonian dynamical system with bound trajectories, which is guaranteed to have a phase-space densely knitted with periodic orbits ($\sim$ closed field-line loops). More details can be found e.g. in Section 2.4 of Zaslavsky (2005) - Hamiltonian Chaos and Fractional Dynamics. So really the closed loops are eliminated mainly by boundary conditions and field divergences.