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Guess Garp wasn't number 1 at time. And again he was defeated with one punch... Perospero did much more than Katakuri in WCI. Perospero is the one going to hell since he got exploded by Pedro. Katakuri was playing with Luffy on mirror world. He could have just escaped there with Brulee and...

Garp beat Chinjao with one punch. He ain't no rival. Such a low class pirate not even 1bi bounty. Garp's rivals was Roger with more than 5bi bounty. Katakuri was no leader at all. Perospero is the right arm of BM pirates.

It's hard to judge those things since Oda doesn't have it clear even for him. Katakuri, Chinjao shouldn't have it. Yamato I guess she should.