He wasn´t in his prime(neither was Garp) but the principle still applies here. Oda was willing to make to a character with a worlds strongest title look bad in comparison to their peers, especially when they seem more plot relevant. There´s no reason to assume he wouldn´t do it again
He didn't have WS title
 
If Shanks dies before Zoro vs Mihawk happens, Shanks can still be > Mihawk without Zoro’s dream being a lie
Do you genuinely think this logic would be satisfying for Zoro? Like this mfker is gonna be ecstatic about being #1 on a bitch-made technicality like what you're putting forth that would put a huge asterisk on his accomplishment? The same guy who avoids fighting dishonourably? The same guy who, right after overpowering and scarring Kaido, was only hung up on the fact he couldn't make him fall? The same guy that never makes excuses for himself?

Are you gonna just pretend that Zoro is a character that half-asses shit and rests on his laurels when we're shown time and time again it's the opposite?
 
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