Warning: This article contains spoilers for Jujutsu Kaisen Chapter 164, "Tokyo No. 1 Colony, Part 4," by Gege Akutami, John Werry and Snir Aharon, available in English from Viz Media.
Hiromi Higuruma's Cursed Technique has been a topic of speculation among fans ever since the character's introduction in Chapter 159. Previous chapters revealed that he has already acquired 100 points in the Culling Game, but an explanation as to how he managed this feat was withheld. When Yuji found the lawyer-turned-murderer in the previous chapter in a theater, he thought Hiromi would hear him out and agree to help him.
However, Hiromi wastes no time in showing that he has zero interest in Yuji's proposal to add a rule that would negate the Culling Game's forced killing and even less patience for the hero's ideas about ending the game altogether. He genuinely believes the Culling Game is wonderful. As negotiations fail, Yuji's only other option is to convince Hiromi by force. Thus, the stage is set for this inevitable fight.
Yuji deduces that Hiromi's 100 points mean he's killed around 20 sorcerers so far. Sorcerers' lives are worth five points while non-sorcerers' are worth one each. Of course, he can't be sure whether his opponent has killed only sorcerers. Given all of the unknowns, Yuji decides to not charge in recklessly and allows Hiromi to make the first move. What might've been a very good idea under different circumstances turns into a terrible mistake. Hiromi's first move is the one sorcerers never want their opponents to use: Domain Expansion. It quickly becomes clear that Hiromi isn't holding back; he fully intends to kill Yuji.
Hiromi's Domain, which he calls Deadly Sentencing, is constructed to appear like a court room, just as anyone who knows his backstory as a lawyer would expect. Yuji attempts to attack him before he can finishing activating his technique, but he's too late. The silver lining is that any and all acts of violence are prohibited in this Domain, for both Hiromi and Yuji. However, this doesn't apply to verbal violence.
Yuji is put on trial by Hiromi's shikigami, which he calls Judgeman. His crime is entering a gambling parlor despite being under the age of 18, which is illegal. Hiromi explains that Judgeman knows everything about individuals inside of the Domain, but this information isn't shared with him. Judgement is based solely on the claims each person presents, though Judgeman also sneaks a piece of evidence for Hiromi to use.
The essence of Hiromi's Domain Expansion seems contrary to what readers have experienced with Domains up to this point. Before Chapter 164, trapping one's opponents in a Domain has primarily been a way to guarantee the user's attacks would hit, and likely kill. Moreover, the user's attacks grow more powerful than they normally are outside the Domain. A Domain that prohibits violence has never been seen before, and it opens the door to the possibility of more creative Cursed Techniques.
The strangeness of Hiromi's Domain reminds Yuji about something Master Tengen had told him: Domains used to be a more common technique for sorcerers in the past, compared to present day. Many Domains now involve deadly, hyper-accurate attacks, but they didn't always function in this way. Domains used to be a way to merely force targets to obey the rules of the user's Cursed Technique.
Constructing a Domain that's meant to be lethal requires immense skill. This is why the number of users have decreased over time. Hiromi's Domain is an old-fashioned one as it doesn't allow those inside to physically harm each other, let alone kill. Furthermore, it relies on a binding vow that requires an explanation of the rules.
Hiromi explains that they both have only one chance to make a statement. Yuji must speak his claim and dispel all doubt, thereby winning an innocent verdict. Hiromi's one statement will be a rebuttal to Yuji's, using the evidence he has, and then Judgeman will decide a verdict. He doesn't tell Yuji what would happen if he's found guilty, but he does tell him that he has three options, which are silence, confession and denial. He also tells him denial may include false statements. Yuji carefully considers each option while keeping the mysterious evidence in mind.
Yuji ends up admitting that he entered the parlor, but lies that he only used the restroom in there, when in actuality he gambled. Hiromi's evidence is a picture of Yuji at a cash exchange window near the parlor in question. He explains to Yuji that he's on trial for entering the parlor, not gambling, so all he needed to do was deny the accusation by saying he's never heard of that parlor. It's a tricky situation in which Yuji digs his own grave by inadvertently confessing because he wasn't aware the crime is simply unlawful entry.
Judgeman finds Yuji guilty and the punishment is confiscation. The Domain is finally deactivated and they are once again back in the theater. Hiromi immediately attacks Yuji with his gavel. He's able to make the gavel appear and disappear as he wishes, and he can change its size. Yuji realizes what Judgeman confiscated after being hit a few times: He's unable to control his Cursed Energy.
Hiromi's Cursed Technique is a very complex one, and it's clear it can do much more. Yuji will have to fight without his Cursed Energy, but, being so naturally strong, that's hardly an issue. He'll have to either win as he is, or somehow escape if the battle turns into a hopeless situation. In any case, he will have to deal with Hiromi eventually in order to reclaim his Cursed Energy. There's also the possibility that Sukuna will help in someway. After all, he wouldn't allow his vessel to die.
