Quick discussion for you guys to gauge an idea, and unfortunately the player most impacted by our decision isn't here to chime in:
At the moment we're using the R.A.W., which says Clerics can Turn Undead as many times as they want. I don't mind this at all, personally. There's an option in the Advanced OSE books that says Clerics can only Turn Undead once per Encounter, probably so they're not so overpowered in an fight. We can vote on if we want to incorporate it, but personally, I have no problem with multiple turning attempts per encounter.
That said, I think we have a situation here where Maloria cast Turn Undead once and was successful. She tried again when more zombies became apparent and failed her 2nd attempt. I think if you're a Cleric with unlimited Turn Undead powers, and you cast Turn Undead and succeed once, but then fail later, all undead that were previously turned are no longer turned. Almost like the Cleric's faith has been shaken or has faltered a moment. I think that's a fair way to play out a Cleric's unlimited Turn Undead attempts: You have unlimited Turn privileges, but failed attempts are a faltering of faith and affect ALL turned creatures, not just the ones you're trying to turn in the immediate moment.
Otherwise, in theory, a 1st Level Cleric could just stand on a tall column out of reach of enemies, and then proceed to turn a hundred thousand low HD undead creatures one at a time. Thirty skeletons could be turned one skeleton at a time, and a hundred rounds later they're all turned regardless of the fact that seventy Turn Undead rolls failed in a hundred rounds of combat, but previously turned undead stayed turned.
It just doesn't make any sense from a storytelling aspect that a Cleric, let alone a 1st Level one, could turn an entire army of low HD undead creatures if given hours and hours to whittle them down one at a time.
I think it should be a situation where Mal cast turn undead, rolled really well, and managed to turn 9HD worth of undead in the Encounter. Later, having unlimited chances to cast Turn Undead, she has to decide if she wants to risk a failed roll, or succeeding her Turn roll but rolling fewer HD worth of monsters to turn than she originally had under her "spell".
If this was the case, as I think it should be, Mal has now lost her turning influence on those previously turned. And probably Mal wouldn't have even tried another attempt this last round, knowing she might risk losing control of the ones already under her diety's influence.
Thoughts?