If you're at the point of using NTFS data recovery tools, you've already lost. With an enormous amount of time, effort, and/or money, you may be able to recover

If you're at the point of using NTFS data recovery tools, you've already lost. With an enormous amount of time, effort, and/or money, you may be able to recover something, although without checksums you'll never be able to validate whatever-it-is you pull out. I wouldn't call it a "manageable" failure. The goal is to never reach this point, via a combination of redundancy and backups. ZFS helps enormously with the first part.