Burton's Batman was very good, but the overall extremely massive success didn't come until TDk or BB. However, '89 Batman is still popular. So, I'd say 2 or 3, but most likely 2 (Batman Forever and Batman & Robin.) Now, BB was the overall "right" route for Batman in people's minds, but like I said, some people still consider Burtons Batman the route Batman, so actually, I'm proven wrong a little here.
It's funny, people use to praise Sam. Now, they dislike him. It's just a cycle that will go on with every comic film franchise. It's annoying, but hey, what can I or anybody do about it? I can