In the past and if only the DC version, I would have said Darkseid even under normal circumstances. Because DC has (or had) this idea that Kirby's idea of the New Gods as more powerful replacement gods to the terrestrial ones like Zeus was to be maintained, which left us with stinkers like Granny Goodness apparently managing to overthrow Olympus on her own.
But, with the New 52, things appear to have changed somewhat and in certain cases the scale of power appears to have been reversed:
Wonder Woman has just spent the last 2 years fighting the First Born, Zeus' son that was certainly within the same kind of physical power Darkseid displayed in the opening JL arc, where he admitedly didn't do all that much.
Zeus has also fought his Fist Born once, on what appeared to be a primodial Earth. But when I say fought, I mean; he and his brothers treated the FIrst Born like a particularly obnoxious insect and Old Testament stomped both him and the rest of the planet (since the part that didn't follow the First Born was dead) for challenging their status quo.
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