That would require a non-lethal way to take down enemies or the NPCs ability to call it quits and surrender/run away.
Skyrim had enemies cowering and mock-surrender, but ultimately get up and start again - a missed opportunity in my book.
The other problem is that the nemesis system is ultimately generic. Those enemies change visually, but you're never quite interacting/talking to them. They don't have plans/contingency plans and grow as characters from failed attempts/mistakes of the past. Which ultimately makes them flat or hollow.
I'd love to see it if they concentrated on just one nemesis that grows alongside you and that you run into multiple times. Might even come out on top and gloat, if he plays his cards right. And have multiple avenues of character growth depending on how those encounters end.
That would be a worthwhile addition and make the game feel more alive.
That would also be complicated and resource-intensive to implement, so I'll hold no illusions on whether it'll done in a game.