You are talking about a graduated ND filter instead of a regular ND filter, right?
HDR can be done to look more natural. But it seems most go for the over-the-top look and its getting old and ugly looking, IMHO. And the all-time reason, but -oh - that's how my eyes saw it. Bull. Manually exposure blending is effective method too and it utilizes a more artistic human touch than the everyone's shot looks the same because they plugged and chugged through the same software.
In short, I'd say you can and may need to employ both methods. A graduated ND filter has limitations. Tall things in the foreground will also vary in exposure with the filter, for example. And exposure blending may not always be practical sometimes too.
Last edited by tuco; 04-18-2012 at 05:22 PM.