Elmer,
What you have proposed is basically a locking tab/plate for the axle nut, but this will not directly resist any torque from the axle itself.
A torque arm is used to resist axle movement by acting directly upon the flats of the axle and preventing it from rotating in either direction (under power and under regen).
Simply locking the axle nuts in relation to the dropouts is unlikely to prevent rotational movement of the axle itself, and therefore should not be used instead of suitable torque arms.
I don't see a problem with using your nut locking tabs/plates in addition to torque arms if you are concerned about the axle nuts working loose over time.
If the axle nuts were able to be torqued up tight enough to prevent the axle from rotating (without stripping the threads), the nuts should not require locking tabs as they could not work loose over time if there was no rotational movement of the axle.
Alan