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afaik, returning is one of the spells that always goes off no matter what the opposition strength is.
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You are mistaken. Shadow Seers are the golems' nightmare. As well as deep seers, btw.
But I'm still not sure this behavior is tied to hp. IIRC, Arch Theurgs have 8 hp normally, but golem can escape. Maybe it is some calculated value of "relative power" what matters when spending gems on returning.