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You have to think about it bro Out of all things Oda could have chose to name this volume he chose this title to label a milestone volume I think he chose it because of the characters on the cover And you also have to think why did Oda chose those characters in particular for such volume cover...

4 of the 5 people on that cover called "supreme king haki" been confirmed or strongly hinted at having CoC So why not the 5th one? :endthis: