For me, it's not so much a matter of how much memory the app uses as much as if it will give it back.
Safari memory use balloons for me no matter how many tabs are open. Closing tabs doesn't get me the memory back (and I've had plenty of cases where I open another app that uses a lot of memory and it just crashes things).
Whereas Chrome will at least give me the memory back when I start closing tabs.
But this is just my use cases... it could be something specific to my machine; I don't know.