A feasible implementation of a novel X-ray detector for highly energetic X-ray photons with a large solid angle coverage, optimal for the detection of Compton X-ray scattered photons, is described. The device consists of a 20 cm-thick sensitive volume filled with xenon at atmospheric pressure. When the Compton-scattered photons interact with the xenon, the released photoelectrons create clouds of secondary ionization, which are imaged using the electroluminescence produced in a custom-made multi-hole acrylic structure. Photon-by-photon counting can be achieved by processing the resulting image, taken in a continuous readout mode. Based on Geant4 simulations, by considering a realistic detector design and response, it is shown that photon rates up to at least 10¹¹ photons s⁻¹ on-sample (5 µm water-equivalent cell) can be processed, limited by the spatial diffusion of the photoelectrons in the gas. Illustratively, if making use of the Rose criterion and assuming the dose partitioning theorem, it is shown how such a detector would allow obtaining 3D images of 5 µm-size unstained cells in their native environment in about 24 h, with a resolution of 36 nm.