Jujutsu Kaisen: Yuji Itadori's Unruly Past Unexpectedly Catches Up With HimJujutsu Kaisen 164 presents a new type of Domain Expansion, one that is far more dangerous than the others.
Although Yuji Itadori is as far from evil as anyone could possibly be, he has dabbled in some rule-breaking from time to time. His defiance of his peers and even his middle school coach was on full display in the series' opening moments. While these specific instances of insubordination may have had no long-term consequence, another from much further back in his history has come back to haunt him.
When Yuji entered a Pachinko parlor as a minor, he committed an illegal act. This occurred in the 16th chapter of the novel. Gambling is strictly forbidden for youngsters around the world. Unfortunately for Yuji, Hiromi Higuruma used this opportunity to unleash the full force of his Domain Expansion against him. Yuji was tried for this infraction while imprisoned in Deadly Sentencing and had to participate in the trial and accept the verdict.
Hiromi's shikigami, which he dubbed Judgeman, presided over the case. Hiromi claims that Judgeman is nearly omniscient and knows everything about everyone in the Domain, which explains how it was able to precisely repeat an event that Yuji himself had almost forgotten. There were no surprises in the court rules; Yuji had to prove his innocence. Hiromi had concocted a piece of proof that would be matched to his story, and Judgeman would issue the ultimate verdict.
Yuji tried to get out of the trial by faking his way out of it. He admitted to going into the parlor but said he merely went in to use the restroom there. If Hiromi's evidence had been different, this approach would have worked. Using Hiromi's photo, Yuji's face is clearly visible in front of a cash collection point on the day of the incident. As a result of his argument, he concluded that Yuji was only in the area to claim winnings from illicit gambling. After seeing the picture, he was doomed. Only two words appeared on the Judgeman's display: "Guilty. Confiscation."
It was immediately after Hiromi's Domain was deactivated that he and Yuji regained their bearings and pursued each other with his hammer. That didn't take long for Yuji to recognize that wasn't a typical hammer. This wasn't Hiromi's most alarming observation; he was able to summon and vanish it at will, as well as modify its size.
You can't control Cursed Energy, Yuji realized. "Confiscation" may have been what Judgeman was referring to. As a result of losing Cursed Energy, Yuji does not suffer greatly. His combat prowess has always been based on his strength and speed. His alternatives have become more limited as a result. In the event of a wave of Cursed Energy, he will no longer be able to employ the Black Flash or defend himself with his own. This sequence of events could be explained by Yuji's long-ago disobedience finally receiving its just reward.
In contrast, Hiromi appears to be in top physical condition. His hammer had already struck Yuji twice, and he was shocked that they hadn't halted it. From his capacity to generate and manage a shikigami, conjure evidence out of thin air, and wield his hammer at whim, it seems likely that he has some kind of conjuring power—possibly with a legal twist—in his Cursed Method.