Water cooling can be many times more efficient.
"many times" is a stretch. *maybe* up to 10% improvement if you significantly drop the temperature 50C or more and maintain same current.
you can drop heatsink temp significantly, but you still have the case-to-heatsink thermal resistance and the junction-to-case thermal resistance to deal with. these are bottlenecks so as soon as you start increasing current your case temp is rising above what your heatsink temp is and now amount of delta T on the heatsink will reduce the amount of heat that needs to flow through those bottlenecks as its directly proportional to input current
Here is a graph of case temp vs flux at a fixed current for CLU048 .keep in mind in the grow world we are generally already operating in the left portion of the curve where it is flatter. this is 1080 mA or ~35W for a citi 1212. on a decent sized heatsink youd have a heatsink temp of ~50C and case temp 60-70C. If you aggressively liquid cool and drop heatsink temp to 0 C you might get a case temp of 10-20C which is an efficiency bump of a little less than 10%
really the only way to know would be to do some direct measurements of par or lumens of a single chip on a passive vs an active vs a watercooled setup, in the latter case starting with room temp water and dropping the temp down to 0 C or less (with glycol below 0 C.). then you could have a direct measurement of the % of efficacy increase theoretically achievable. In practice if you built a rig that was able to vary temp (with increased cooling load on an increased deltaT), youd want to do measurments of light intensity with the entire system including lights and cooling system on a single killawatt plug to determine overall energy input for overall light output
keep in mind that unless you live in a nice alpine climate (where cooling is less of a benefit anyway), you are paying money to produce cold water. Even a basic liquid-to-air heat exchanger uses a fan, you have pumps to pump the water around, etc.
A large temp drop such as 50C drop would require a chiller. so now you are investing money on hardware to get an efficiency gain. so say you have 1000W of lights to cool. by aggressively liquid cooling them you may be getting up to 8% more efficacy out of them, but any energy used by pumps, fans chillers etc will be counted against that. chilling water isnt cheap and you can suck up that 80W pretty easily and be right back where you started.
as a point of reference most residential hot water hydronic heat systems (boiler on the heat side and baseboard radiators, domestic water heater coils, or in-slab/in-floor pex on the load side) are designed to operate with a 20F(10C) temperature difference. so water enters your boiler at 140F/60C and exits at 170F/70C. the 170F/70C water is carried to the load where it gives up heat and again is 140/60F on its way back to the boiler.
depending on the size of your cooling system, water slightly warmer than room temp (30C) going back to your lights is probably practical. look up at the chart and see what 30C heatsink temp vs 50C heatsink temp is - its 5% bump at most so now you only have 50W of savings to work with to cool your lights. a circ pump and simple passive cooler can easily be 50W even without active chilling so youre always working against diminishing returns
in most cases its just as simple and cost effective to increase number of emitters in a given area to drop the current and case temp of the chips and achieve same results