Even if it's fodder nin, it's still an entire body to utilize the jutsu. As well, it's a Forbidden Jutsu because it uses a body to be cast, not because it's necessarily ultra-powerful, it's just a taboo thing to do.
And we also know that the zombies aren't at full power, or at least they weren't against the 3rd. I guess it's possible, but I don't think an old 3rd Hokage was stronger than the first alone, much less the 1st, 2nd and Orochimaru.
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