Ohr Bak Sui, the leader of the "Falling Cow Sect" (yeah, really), was murdered by Mo Yung Bok, who used Ohr's own signature whip skill against him (the Mo Yung Family's infamous "Thy Way Upon Thyself"). When Golden Abacus Tsui and Soul-Chasing Whip Gor discussed the murder with Prince Deun Jing Tsun of Dali, Prince Deun wondered aloud, "Whose martial arts could be so advanced that even Master Ohr couldn't defeat him?"
Prince Deun's remark makes it sound like Ohr was some invincible wulin elite, but I doubt Ohr was anywhere near as good to merit such praise. Ohr Bak Sui was unlikely to be able to credibly sustain the kind of reputation such a flattering remark suggests in a wulin world that knowingly hosted Kiu Fung, Kau Mor Tze, the six monks at Heavenly Dragon Temple, the Yeun-generation monks at Shaolin, Deun Yin Hing, King Deun Jing Ming, and Ding Chun Chou (we'll leave out the unknowns such as the Janitor Monk, the Siu Yiu Sect Elders, Siu Yeun San, and Mo Yung Bok, and the up-and-comings such as Deun Yu, Hui Juk, and Yau Tan Tze). I guess Prince Deun was just being courteous and respectful per wulin etiquette, but I reckon that Ohr Bak Sui was probably only a little better than the three junior Great Evils. At most, I'd allow that he was perhaps as good as a Yeun-generation Shaolin monk.