In the complex power system of Jujutsu Kaisen, matchups often come down to specific interactions between techniques rather than raw power levels. Toge Inumaki's Cursed Speech versus Heavenly Restricted individuals such as Maki Zen'in and Toji Fushiguro represent one of the most intriguing potential power interactions in Jujutsu Kaisen.
These enhanced sorcerers demonstrate superhuman abilities, making them powerful enemies, but their absence of cursed energy makes them unexpectedly susceptible to cursed energy spoken commands.
The mechanics of this interaction remain unexplored in canon, but by examining how both abilities function within the established rules of Jujutsu Kaisen's power system, we can theorize about what might be one of the most dangerous counters to Heavenly Restriction users.
Disclaimer: The speculations and opinions expressed in this article belong solely to the author.
Vulnerability of Heavenly Restriction to Cursed Speech in Jujutsu Kaisen
The effectiveness of Cursed Speech appears to hinge on the difference in cursed energy between the user and the target. When Inumaki faces opponents with substantial cursed energy, like special-grade curses, he must employ stronger commands that place greater strain on his vocal cords.
His technique works by channeling cursed energy into his words, forcing the target to comply regardless of their will. Importantly, Cursed Speech doesn't require the target to possess cursed energy to be affected—it's the enforcing mechanism that utilizes cursed energy, not the receiving end.

Heavenly Restriction, as seen in Maki and Toji, represents a cosmic trade-off: in exchange for having zero cursed energy, they gain extraordinary physical capabilities. Their bodies operate on a different paradigm entirely—they cannot see curses without tools, yet possess strength, speed, and reflexes far beyond ordinary humans.
Also read: Taming Mahoraga would've hurt Megumi more than it would help him
This absence of cursed energy means they lack the natural barrier that might normally resist or diminish technique effects. This creates a fascinating vulnerability theory: without cursed energy to serve as a buffer or resistance against Inumaki's commands, would Maki and Toji be completely susceptible to even his simplest orders?
Commands like "stop," "freeze," or "sleep" might bypass their formidable physical abilities entirely, rendering their superhuman bodies temporarily useless.
Potential resistance of Heavenly Restriction to Cursed Speech in Jujutsu Kaisen
Counter-arguments exist, however. Heavenly Restriction might grant them not just physical enhancements but also a supernatural will or resistance to manipulation. Their bodies, optimized beyond human limits, might process and reject foreign influences more efficiently.
Additionally, their extreme speed could allow them to interrupt Inumaki before he completes his commands—though this tactical advantage isn't relevant to the theoretical mechanics of the interaction.
Another consideration is whether Cursed Speech targets the body directly or works through manipulating cursed energy within the target. If it's the latter, Maki and Toji might be immune precisely because they have nothing for the technique to manipulate. However, given that Cursed Speech affects ordinary humans with minimal cursed energy, the former seems more likely.
Also read: Nobara getting sidelined for Culling Game Arc was a blessing in disguise
The Jujutsu Kaisen universe often thrives on these unexpected interactions between techniques, creating situations where seemingly invincible abilities have specific, hard counters. Perhaps the greatest weakness of Heavenly Restriction isn't facing overwhelming cursed techniques but rather confronting abilities that exploit the very absence that grants their strength.
Conclusion
The question of Cursed Speech versus Heavenly Restriction illustrates what makes Jujutsu Kaisen's power system so compelling: it's not simply about who has more power but how those powers interact in unexpected ways.
While Maki and Toji's incredible physical prowess makes them formidable opponents against most sorcerers, Inumaki's unique ability might represent the perfect counter to their specific condition.
Until Gege Akutami explicitly addresses this interaction, the possibility remains that the seemingly unstoppable force of Heavenly Restriction might be vulnerable to nothing more than a few carefully chosen words.
Also read:
- Mahito, not Sukuna, is Jujutsu Kaisen's best-written villain, and the fan reaction he elicits is proof
- Todo's updated Boogie Woogie teased the pinnacle of Binding Vow potential in Jujutsu Kaisen
- Kenjaku, not Sukuna, needed a Heian Era flashback the most in Jujutsu Kaisen