It was 32 in A5 mode(d3d_tranform = 0) and in A5. They didn't use DirectX for dynamic lights back then so it was capped at 32 instead of 8. d3d_transform is gone as is A5 mode, so unless there's still a way to use the old software ligths...that 32 should be removed.
My User Contributions master list - my initial post links are down but scroll down page to find list to active links
