The following contains spoilers for Jujutsu Kaisen Chapter 198 "Sakurajima Colony, Part 8," by Gege Akutami, John Werry and Snir Aharon, available now in English from Viz Media.
While still getting used to the full scope of her abilities, Maki has already stressed that she is now one of the most dangerous Culling Game players and truly among the upper echelon of Jujutsu Kaisen's more powerful characters. She’s already mastered the ability to sense curses -- among other threats surrounding her -- without necessarily having to see them, but Chapter 198 highlights the benefits to her lack of cursed energy. Apparently, none of the general rules of Domain Expansions work on Maki at all.
Right before Maki could finish Naoya off, the latter succeeded in debuting his womb-like Domain Expansion, the Time Cell Moon Palace. At first glance he seemed to trapped Maki inside his Domain, along with the two new Culling Game players, Hagane Daido and Rokujishi Miyo. Naoya’s Projection Sorcery cursed technique was instantly applied to the two reincarnated sorcerers, freezing them in place -- but Maki had vanished into thin air.
Time Cell Moon Palace’s guaranteed hit attack forced each of Hagane’s and Rokujishi’s cells to move in the same manner as Naoya himself. Since this task was almost impossible, the effect of Naoya’s Domain was that those trapped within had to remain still at all costs -- or rip minute tears in their very cells. Just crouching into battle-ready stances opened several lacerations on Hagane's and Rokujishi’s bodies. Both were covered in blood within moments; even movements as subtle as breathing weren’t exempt from this punishing rule.
After relishing in his Domain's effect on the two reincarnated sorcerers, Naoya finally turned his attention to Maki and discovered to his surprise that he couldn’t sense her at all. Even without cursed energy, her presence should’ve been apparent at all times to Naoya since it was his Domain. He remained oblivious to Maki’s presence, however -- until her sword suddenly sprouted from his chest.
Maki’s lack of cursed energy, which used to be an impediment in her work as a jujutsu sorcerer, turned out to be her salvation in this eerie domain. Just like she could travel freely within the Culling Game's various colonies, Domain Expansions had no means to restrict Maki to their borders without her consent. Since Maki possessed as much cursed energy as an inanimate object, Naoya’s domain treated her as the same, allowing her free entry and exit as she pleased -- but this wasn’t the only boon she enjoyed.
A second effect of Maki’s lack of cursed energy was that Naoya’s domain had no way to locate her within it. Even when she chose to remain within its range, his Projection Sorcery technique, which was built into his Domain’s Guaranteed hit effect, would still regard Maki as an inanimate object and ignore her altogether.
Even “one-shot” domains like Satoru Gojo’s Infinite Void or Mahito’s Self-Embodiment of Perfection would be ineffective against Maki. This latest development in Jujutsu Kaisen only further iterates how different Maki’s strength is to that of other sorcerers, and solidifies her equal status in all aspects of strength to the terrifying Toji Zenin.