Contains spoilers for the latest chapter of Jujutsu Kaisen
In the world of Jujutsu Kaisen, no two sorcerers could be more different than Nobara Kugisaki and Naoya Zenin. However, they did share one major similarity, namely the way in which they apparently died. Naoya's surprising resurrection, however, strongly suggests that Naoya's return, albeit in a different form, is more, rather than less likely to occur.
Nobara was allegedly "killed" in a battle against Mahito in Jujutsu Kaisen Chapter 125. After outsmarting him by making him think she was "above her head" in a fight with him, Nobara was able to get close to him to launch a "resonance" against his soul. Realizing that he was close to defeat, Mahito traded places with a clone. In the confusion, it was Mahito's chance to bait Nobara, which he did with devastating effect by being able to touch her face. Within minutes after the attack, Nobara was dead. On the other hand, as the last man standing in defense of the Zenin Clan, Zaoya had to take Maki out in Jujutsu Kaisen or give his best efforts at least, after she laid waste to all the of her immediate family. Unfortunately, he was unsuccessful as a newly empower Maki obliterated him on the family compound.
The relevant point in the case of both deaths was that a sorcerer was killed without cursed energy. Nobara was killed by Mahito, a cursed spirit. However, Nobara's successful resonance attack against Mahito in Jujutsu Kaisen Chapter 123 insulated her from his idle transformation technique. Her alleged death was the result of "plain and simple" physical trauma to her skull. Naoya was killed by Maki in Jujutsu Kaisen, who at that point in time was no longer a sorcerer. That is, Maki just pummeled him to death with her fists. As pointed out in Jujutsu Kaisen Chapter 33, if a sorcerer is not killed by cursed energy, they will be "resurrected" as a vengeful spirit.
Perhaps due to Naoya's absolute contempt for Maki or the way that he was killed by her, the manifestation of Naoya's Vengeful Spirit occurred within weeks of his ing. Moreover, being based on his abilities before he died, it is a powerful curse. At present, there has been no sighting of Nobara's Vengeful Spirit in Jujutsu Kaisen. This may be due to the fact that Nobara was not immediately killed by Mahito's attack but rather did receive medical and cursed energy-based treatments. However, assuming that she has, or will eventually die, her Vengeful Spirit will eventually make its appearance.
While Vengeful Spirits have traditionally exhibited evil intentions and preyed on humans, there are some, such as Rika Orimoto, that can jujutsu sorcerers in their mission. There's no Jujutsu Kaisen rule requiring a resurrected Nobara spirit to be as evil as Naoya. In fact, based on her life and experiences, she'd surely come back his her vengeance squarely focused on Kenjaku and other top-level cursed spirits and their facilitators.
Jujutsu Kaisen is available now from Viz Media.
