If you're letting them go - taking care to not rip their mouth apart and taking time to revive the ones that are beat up pretty bad maybe 15.
If you are a commercial, in your fish-catching prime and motivated by money, and knowing how much you can horse them, and not caring if you rip their face off when you disgorge the hook, and throwing them in a pile behind you rather than reviving them: 25...maybe more.
I've known commercials who can beach a 20 in under three minutes...
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