It really just comes down to whether Gojo or Sukuna pull off a domain expansion.  Which is definitely possible. Yeah, technically cell or Frieza should be fast enough to prevent it, but thats ignoring that in Dbz characters manage to fire off attacks that take a few seconds to charge up all the time. and cell can be straight up baited into taking an unknown technique at full power to the body. I think if cell and Frieza are unaware of domain expansions they could easily lose getting caught off guard.