Jujutsu Kaisen chapter 198: Maki’s victory over Naoya breaks Akutami’s own rule

Maki Zenin and Toji Fushiguro in Jujutsu Kaisen (Image via Sportskeeda)
Maki Zenin and Toji Fushiguro in Jujutsu Kaisen (Image via Sportskeeda)

Jujutsu Kaisen chapter 198 leaked spoilers have confirmed that Maki will defeat Naoya and emerge as the winner of the battle in the Sakurajima Colony arc. However, fans have expressed mixed reactions to this, stating that the battle feels rushed and underdeveloped.

But more pressing is the fact that this fight upsets mangaka Gege Akutami’s descriptions regarding how curses and vengeful spirits function in the Jujutsu Kaisen universe. This article analyzes the battle between Maki and Naoya while keeping in mind confirmed theories mentioned in the manga and official fanbook to determine if her victory was unrealistic.

Disclaimer: This article takes into account the author’s opinions and contains spoilers for the Jujutsu Kaisen manga. All external media in this article are the property of their respective owners.

Why Maki’s victory over Naoya in Jujutsu Kaisen chapter 198 upsets Akutami’s concept of how vengeful spirits work

Established theories about jujutsu and cursed spirits in the series

Rika Orimoto as a vengeful spirit (Image via Gege Akutami/Shueisha)
Rika Orimoto as a vengeful spirit (Image via Gege Akutami/Shueisha)

Jujutsu Kaisen has introduced theories about how curses function early on in the series, even in the prologue focusing on Yuta Okkotsu. The series classifies curses based on their origin, categorizing them into cursed spirits, vengeful spirits, imaginary vengeful cursed spirits, and so on.

Vengeful spirits, specifically, are humans who become curses after their death. Sorcerers face a greater probability of turning into vengeful spirits unless killed by jujutsu, but non-sorcerers can turn into curses if their deaths are cursed.

Naoya Zenin was killed by Maki’s mother who stabbed him with a knife without using any jujutsu, enabling him to return as a vengeful spirit. The Jujutsu Kaisen official fanbook also mentions that powerful vengeful spirits possessing enormous amounts of cursed energy are often impossible to exorcize and must be sealed away, as was the case with Sukuna and Rika Orimoto.

Another core concept introduced in the series pertains to Domain Expansions. As Gojo taught Yuji while within Jogo’s domain, the only surefire way to escape a jujutsu-user’s domain is to cast one’s own domain. The more refined domain reigns supreme, with the weaker one dissipating.

But it is possible to break into a domain using brute force, since the more reinforced a domain is on the inside, the more fragile it is from outside. Yuji was thus able to break into Mahito’s domain to rescue Nanami, and with Sukuna’s innate domain being much more refined, Mahito’s domain fell apart immediately.


Jujutsu Kaisen has already confirmed in the past that Maki Zenin and Toji Fushiguro share the same Heavenly Restriction, granting them superior reflexes, athleticism, and sharpened senses. Toji was on equal footing against Gojo, even overpowering and almost killing the latter. But Gojo was nowhere near the peak of his abilities at the time, not even having mastered Domain Expansion.

After awakening the true potential of Limitless and Six Eyes, he killed Toji, so there is no way to confirm how the “Sorcerer-Killer” might have fared within his domain. Even during his battle against Suguru Geto, he was only able to deal with the imaginary vengeful cursed spirit, Kuchisake-Onna’s domain with the Inverted Spear of Heaven, which nullified all types of jujutsu.

How Maki’s victory upsets the core concepts of the series

The Sakurajima Colony arc of Jujutsu Kaisen made it abundantly clear that Naoya is a vengeful spirit who is deserving of the special-grade classification. His rapid evolution and persistence is evidence of his vast cursed energy, though it is debatable if it can be comparable to Rika Orimoto’s endless reserve of cursed energy.

During his lifetime, Naoya was a powerful sorcerer and becoming a vengeful spirit has further evolved his original Cursed Technique. This has also dramatically bolstered his cursed energy levels, allowing him to cast his domain despite having his entire torso sliced in half.

Maki's immunity to domains (Image via Gege Akutami/Shueisha)
Maki's immunity to domains (Image via Gege Akutami/Shueisha)

While Jujutsu Kaisen chapter 198 spoilers do explain that the domain failed to sense Maki on account of her having no curse energy, Maki killed Naoya with a single strike clash against the power level he displayed in previous chapters.

Considering how much cursed energy Naoya possessed as a vengeful spirit, it is unlikely that he would go down so easily within his own domain, which is considered the strongest weapon in a jujutsu-user’s arsenal.

Toji trapped in the Kuchisake-Onna's domain (Image via Gege Akutami/Shueisha)
Toji trapped in the Kuchisake-Onna's domain (Image via Gege Akutami/Shueisha)

It can be argued that he was already weakened after being slashed twice before by Daidou, and the strikes from the cursed sword in Maki’s hand proved to be the final blow. But the chapter states that Maki cannot be restrained within any domain without her willingly entering it, which contradicts Toji’s encounter with the Kuchisake-Onna’s domain that trapped him against his will.

Furthermore, the loophole in the conditions required for the sure-hit element of Naoya’s domain seems to be exactly suited to mask Maki’s presence, which seems a little too convenient.

The Sakurajima Colony arc has been building up the anticipation for Maki and Naoya’s final showdown, with each Zenin cousin one-upping the other at every turn. The Domain Expansion reflected Naoya’s final form and fans expected him to be a difficult opponent to deal with.

The ease with which Maki exorcized him and dismantled the domain negatively affects the credibility of how powerful Domain Expansions are, and appears to solely be for the purpose of establishing Maki as the new Toji in the Jujutsu Kaisen universe.

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