The limitations on Attunement slots really puts the kibosh on walking around with dozens of magic items, however.
That said, you can use the rules for Boons and magical gifts to justify the bonuses if you don't want magic items all over the place. The evil general who is walking around with the blessings of the dark gods to enhance his natural martial prowess is certainly in genre for most iterations of D&D.
Remember that giving the opponent Resistance to common damage types can effectively double his HP without having to 'actually' double it. So if a demon or fey or something made him Resistant to Bludgeon. Piercing and Slashing damage he has twice the survival chance in most fights with PCs, especially if he also Resists the magic users favorite attack spells.
There's
way more problems with handing out permanent magic items like candy then 'Well, they can wear dozens of them'. Even ignoring that three major magic items plus however many minor ones is still a lot, you also create the problem in that too much magic once more focuses the experience on your equipment over your character skills. The treadmill of 'You must always be getting better gear!' is pretty toxic to a game in my experience, plus there's the issue that even in a High Fantasy universe, too many magical items make them not just mundane, but boring. I really don't wanna run into the Skyrim problem where the reaction to stumbling across a super awesome magical item is 'Meh, not worth the weight of picking up and selling it for gold'.
There's a reason that the 'starting equipment' for high level(17-20), high magic games still only recommend two rare magic items, 1 very rare, and 3 uncommon. Even 11 through 16 it suggests only 1 rare item and a few uncommon ones.
And yes, given the setting has extremely active divine intervention (PC leveling is mostly justified as divine blessings, and there's even a Divine Favor mechanic), enemies getting blessings of their own is something I planned on. Though, heh, it's predominantly going to be 'the blessings of the gods of Light' for the antagonists of his game.
And indeed, Resist is powerful.
In that case, I would recommend another system.
REIGN and GURPS (Banestorm being an excellent example of a mostly dungeon-less setting), both do high fantasy well, without making npcs worth less to adventurers than their animated corpses.
Yeah, though I think we may have an issue of differing definitions of High Fantasy, because both of those games trend heavily toward the gritty side of things (Yes, I know GURPS is a 'universal system', but universal systems really aren't). I'd hazard that I'm also thinking a good deal more High Magic than you are, as those games can probably be modded toward say, Lord of the Rings, easier than what I have in mind.
Also, making NPCs in Gurps takes too long. REIGN would be better, especially with copious amounts of mook rules, but still...
That said, REIGN does actually have a D&D based mod around that might be useful inspiration for how to handle Paladins and such. Eh. I'll consider it. At least REIGN does power scaling rather decently.
