I guess you can say Batman in Batman Begins was less direct in his killing, as opposed to Batman in Batman REturns when he strapped a fricckin bomb to a goon's waist or in Batman 1989 when he threw the goon off the cathedral. Batman bombing the ninjas in BB can justify it because he "allowed them to escape" amidst all the mayhem despite blowing their house apart. Just like he "allowed" Ras to save himself on the train, as farfetched as that sounds.
In fact, in BB, the idea of not killing is more expressed due to that scene with Rachel slapping Bruce for carrying a gun and wanting to kill Joe Chill. In Burton's Batman, Bats just goes and takes care of things and casualties occur without remorse. They never emphasized that Batman doesn't kill.
But yea, the line's very blurry and I think in all the movies, his actions led to death some way or another.