Jujutsu Kaisen established that a sorcerer can make a Binding Vow to get something if he or she makes a sacrifice in return, which leads to a lot of fascinating possibilities in the story. Therefore, some people have theorized that a sorcerer could make one of these vows to get a Heavenly Restriction, such as the one Toji Fushiguro had, but this is something that cannot be possible.
In that regard, it has been established in the Jujutsu Kaisen franchise that a Heavenly Restriction is something that a person can only achieve from birth and isn't something that can be obtained through conventional means in the story. That means that a Binding Vow wouldn't make that possible, which could explain why some characters didn't go for that approach, such as Kenjaku.
Disclaimer: This article is a speculative theory and reflects the writer's opinion.
Explaining whether a Binding Vow can be used in Jujutsu Kaisen to get a Heavenly Restriction or not

It has been established in the series that a Binding Vow is the ability of a sorcerer to strike a deal to get something in return in exchange for something else. This came into full fruition during the final arc, Shinjuku Showdown, since the main antagonist, Ryomen Sukuna, made use of multiple Binding Vows, hence why a lot of fans have theorized that it could be possible to do one for the Heavenly Restriction.
A Heavenly Restriction is a condition where a person is born without Cursed Energy and gains superhuman strength (such as Toji Fushiguro or Maki Zen'in) or extremely poor physical conditions with a tremendous range for Cursed Energy usage (Mechamaru). Therefore, a Binding Vow cannot make this possible since this is something that a person can only achieve through birth and nothing else.
It is also worth pointing out that the nature of Binding Vows is somewhat inconsistent since the author, Gege Akutami, never fully explained the limitations of this system. Much like the Black Flash, there is no real confirmation of where this concept comes from, and that can lead to many theories, such as this one.
The ideas of Heavenly Restriction and Binding Vows

The concepts of Binding Vow and Heavenly Restriction might be two of the most peculiar elements of world-building, along with the Black Flash, in the Jujutsu Kaisen series, since they are a lot more abstract. No real metric or factor leads to a person being born with a Heavenly Restriction, seemingly the being luck of the draw, and characters such as Satoru Gojo have stated that no one can know when a Black Flash is going to appear.
This abstract nature could be intentional by Akutami or could be one of the running issues that the story wasn't developed, especially considering that someone such as Kenjaku could have made use of the concepts of Binding Vow and Heavenly Restriction. Especially considering that he was seen changing from one body to another for centuries, so he could have gotten a greater grasp of these elements.
Final thoughts
Based on what was established in the lore of Jujutsu Kaisen, a Heavenly Restriction can only be obtained through birth. Therefore, the use of a Binding Vow wouldn't make that possible, which solves a question plaguing the fandom for a while.
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