No...why would the special offroad package axle that is only on the OR and the manual trannies be the weakest on your list. It is bigger than the 200 mm one on the SE.
the nissan-ized hybrid D44 is also fullsize truck axle tube thickness and 32 splines vs 30 splines and a thin dana 30 axle tube thickness on the d44 jeep units. the ring gear size is still smaller than the earlier nissan minitruck axles though and the one piece housing with the dropout carrier is always a plus (like a ford 9 inch except metric).
the list would be more like
old nissan rear
titan/OR Xterra D44
dana 44 jeep
200 mm nissan base rear axle new fronty/X