In Jujutsu Kaisen, the main power system allows sorcerers to utilize their Cursed Energy by manifesting it through their Cursed Techniques. These techniques are unique to each person and can range from being barely effective to allowing the user to take over an entire country by themselves, which is where the classification for Special Grade comes from.
However, when all is said and done, and these techniques have been stripped away, everything boils down to hand-to-hand combat. When push comes to shove, sorcerers reinforce their bodies with Cursed Energy and fight using their strength and martial skills. These fighters, in particular, can certainly hold their own in a physical fight.
As one of the heavy hitters of Jujutsu High, Hakari is considered by most to be at the level of the Special Grades in terms of strength, and is even considered by Yuta to be his equal. Unlike the other strongest characters in the series, Hakari's strength doesn't come from a world-ending technique, though his technique certainly helps his hand-to-hand fighting.
Essentially, Private Pure Love Train allows Hakari to constantly open his Domain, which gives him unlimited Cursed Energy and automatic Reverse Cursed Technique. Due to the safety this ensures, Hakari goes full offensive mode while in the jackpot state, which is done completely through his physical strength and hand-to-hand skills.
Although Modulo Yuji is widely thought to be the strongest sorcerer in history, with power greater than even Sukuna and Gojo, he has no physical-only feats that can be used as a gauge for his hand-to-hand strength. Still, Yuji, during much of the original series and the Sukuna Raid, proved his incredible power.
Although he didn't initially have Shrine or Blood Manipulation, Yuji's Divergent Fist was a technique that inflicted double damage, so his strength when using hand-to-hand methods was quite formidable. Plus, his physicality was always greater than almost everyone else's, so he became an immensely powerful physical combatant by the end of the original series.
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The Culling Game saw the awakening of many ancient and powerful sorcerers, though one existed at the very top of the list. This was Kashimo, and he went through the entire event without awakening his body-destroying Cursed Technique, using only his immense strength, speed, and Cursed Energy manipulation to defeat his foes.
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