Giving the benefit of the doubt to that possibility is fine if its even emphasized more than just a throwaway line.
Fine, I'll say there's a CHANCE it could greatly effect him which would lead to his victory.
It all comes down to how powerful you think the passive effect is.
He didnt tank, he borderline no sold a red from a Gojo who was already the Strongest sorceror.
Getting put on your ass and bleeding from your forehead isn't no selling my guy.
I'll admit that he didn't take life altering damage but if you get hit by an attack like that and call your opponent a monster it clearly did more than a little bit of damage.
Those two characters arent Toji or current Maki. Zero cursed energy is on another level compared to partial HR, we're talking about reacting to mach speed stuff while Makis best feat with partial HR was catching a bullet... do you see the difference?
Yes, I know the difference is huge but the gap isn't as big as you're making out to be. Let's high ball and say Toji is 10-20x as durable as Maki was in Shibuya. That would still mean he's taking serious damage from a random flame blast from Jogo
I don't wanna sound like a broken record but I don't think people realize how crazy strong Jogo was. A random flame blast one shot Maki and had her on her deathbed even with treatment. They didn't even think she'd make it through and this is Post Shibuya.
While that same flame blast wouldn't kill Toji it would definitely have him reeling.
Besides, like Maki showed - Toji can passively heal as well like how Maki healed herself while Kamo bought time.
They can heal but we don't know the limits of their natural regeneration so it's impossible to speak on that. We just don't know enough.
Can they regrow their skin, can they heal damage dealt by burns instead of blunt force, can they regrow limbs, etc. These are all things that we have no answer to at the moment