Why over expose either? Why not properly expose. In Thom's review
of exposure comparing the S2, D100 and D1X he mentions the extreme
touchiness of the D100 in exposure.
The exposing for highlights is a film trick. This is not film!
Noise is also a consideration and so are shadows. I have lost
shadow detail trying to shoot for highlights in some shots and
every camera has different curving characteristics. And if you read
Thoms comparison you'll see that the D100 (I use it because the D70
looks like it has a similar characteristic), you can see that with
underexposure the noise level ramps up very quickly. With
overexposure you also introduce noise in certain shots. So, the
conclusion is to expose as correctly as possible.