Sukuna’s Malevolent Shrine is one of the most powerful techniques in the Jujutsu Kaisen universe. This domain expansion allows Sukuna to indiscriminately cut down anyone in his path and do it in the blink of an eye. Sukuna is a monstrously powerful individual and the strongest sorcerer in the history of JJK, and as such, it is no surprise for the fans to see that his Domain Expansion is among the strongest.
That said, the Malevolent Shrine isn't invincible. One can protect themselves from this Domain Expansion in a plethora of ways and counter the King of Curses efficiently.
Falling Blossom Emotion is a very special anti-domain technique that is only common among the members of the Big Three families in JJK. Fans have seen Naobito utilize this powerful technique, and during the Shinjuku showdown arc, Gojo also utilized this power against Sukuna. It sees the user coat their body in cursed energy, which acts as a counterbalance to the cursed energy in the incoming cursed Technique and neutralizes it to a certain degree.
When Gojo used this technique against Sukuna, he was able to take the sting off the slashes that were sent his way using this power and, as a result, buy himself quite a lot of time. It can't fully counter Malevolent Shrine, but it most definitely can be the difference between life and death.
Simple Domain is one of the most efficient ways to counter Malevolent Shrine. In order for anyone to survive a Domain Expansion, utilizing the power of Simple Domain is extremely important. Simple Domain sees the user create a small spherical domain around themselves, and this domain acts to counter the effects of a Domain Expansion and protect them from the sure-hit effect as well.
However, against stronger techniques, a Simple Domain can end up breaking. It depends on how great the grasp of an individual over a Simple Domain truly is. Fans have seen many powerful uses of Simple Domain over the years, and Gojo stands out as one of the best. In Shinjuku Showdown, Yuji used his simple domain to withstand Malevolent Shrine for 99 seconds. Meanwhile, others like Choso and even Miwa managed to do so.
Hollow Wicker Basket is a very old but effective way to protect oneself from a Domain Expansion. It has worked against some of the strongest domains, and as such, there is no reason for one to think that it wouldn't work against Malevolent Shrine either.
This technique sees the user clasp their hands together to create a particular hand sign, which then creates a basket-like dome around them. As long as their hands are tied together, the dome stays active and protects the user from the sure-hit effect of any Domain Expansion, such as Malevolent Shrine. Using this technique, Sukuna was able to protect himself from Yuta's sure-hit effect inside Authentic Mutual Love for quite a while.
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