I don't see why Safari would have a need for more RAM... We're talking about a phone here, not a desktop computer.
The phone can mostly only display a single window at once. Applications in the background only need to be active if they're actually doing something in the background - and if they are, only the active portion of the applications really needs to be loaded in RAM. There is no point in keeping the fully loaded tabs of Safari in RAM when Safari is not in the foreground: there is no background processing being done there. Keeping these tabs in RAM would only deprive the application in the foreground and the active applications in the background of that RAM.
That's why iOS works well with a low amount of RAM : it's only used when it is needed and the OS is pretty aggressive about giving that RAM to the applications that really need it.
The problem with Safari is not with a lack of RAM (I suspect Safari would behave the same even with 64 Go of RAM), it's not a problem with the OS (the design is good, the application gets all it needs to implement different strategies), it's really only a problem with the strategy chosen for Safari.
You could solve tab reloading without any additional RAM, you just need to serialize the tab content to the filesystem everytime you need to free some RAM and then reload it from the filesystem when it is needed again (with necessary checks to avoid stale content). Doing that, you can have dozens of tabs without needing any additional RAM, at the cost of some disk space.
I suspect some alternative browsers might do that, especially if they are power users oriented. Safari is certainly not power user oriented, and the strategy chosen by its developers makes sense if you consider the average user use case with only a couple of tabs opened and mostly forgotten instead of manually closed.
Depending on how fast flash storage is on the iphone though speed and such could take a hit by passing off the tabs to flash storage instead of RAM. That is a solution though, I've said it before too that apple should allow a option for that. I'd give up a couple gigs of my storage for a swap partition without hesitation.
"There is no point in keeping the fully loaded tabs of Safari in RAM when Safari is not in the foreground"
I disagree with this heavily by the way. Maybe you haven't found a reason for it but it's silly to say objectively there isn't a reason for it. I browse 4chan heavily and if I'm in the middle of a thread and I have my spot saved and the location where I made my post and then the tab reloads on me I have to go through hundreds of anonymous posts to find mine and find my place in the thread meanwhile theres tons of new posts because it reloaded as well.
It also messes up post tracking but if you don't use the site I can't really explain that very well.
That's just one example too.