I would consider a D44 under a relatively light rig with only 35's to be fairly beefy. I have heard the "no bigger than 35's on a D44" before but that was considering a heavy fullsize truck with more power.
I've wheeled with several guys with D44 front axles under 6 cylinder Jeeps and they have had really good luck. Two guys had D44 fronts under YJ's with 36" SX's (i.e. heavy), lockers, low geared t-cases, but stockish 4.0L. Both of these guys were running these fronts back in the late-90's when running a D60 front was unheard of, and no fancy chromo shafts or u-joints either.
Another guy just built a D44 for his CJ-7 with 33" Boggers and a built 258. He's been intentionally beating on it to see how it holds up, especially considering he was constantly breaking the old D30 (granted, it was a CJ version LP with the small joints).
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