One of the most brutal massacres in wulin history was the Battle at Tsui Yin Manor in DGSD, when Kiu Fung notoriously slaughtered dozens upon dozens of wulin warriors singlehandedly.
Kiu Fung isn't the most powerful fighter in DGSD; several others can match him, and a few others even surpass him. That said, few warriors have ever fought as savagely as Kiu Fung, which explains the unusually high body count.
If the target of the Tsui Yin Manor warriors had been someone equivalent to, but less violent a fighter than Kiu Fung such as Mo Yung Bok or Kau Mor Tze....or someone much more powerful, but also far gentler such as Hui Juk, would the casualties have been lower, or would just as many (if not more) people have died?