Despite not growing up together, Maki and Toji had a very similar childhood as disgraced members of Jujutsu Kaisen's notorious Zenin Clan. Both were considered failures by one of the most powerful families in Jujutsu society because they were born without cursed energy. They overcame their family's disapproval and developed into commanding opponents, despite the fact that they aren't yet considered to be Jujutsu sorcerers.
Upon registration, each Jujutsu sorcerer receives a rank, starting at Grade 4 and progressing to Grade 1. In the world of Jujutsu, there are only four Special Grade sorcerers at the moment, though occasionally a very powerful sorcerer will be placed in this group. Even though Maki and Toji overcame all obstacles and increased their strength to a level that was superior to the majority of sorcerers with cursed energy—Toji even vanquished curses that Grade 1 sorcerers had trouble with—they are still unable to be Special Grades.
Jujutsu Kaisen Reserves the Ranking Scale for Sorcerers
Because Jujutsu Kaisen is only for certified Jujutsu sorcerers, its creator Gege Akutami is not a fan of Maki and Toji being listed on the grade scale. The reason why the grade of third-year Hakari Kinji is never made public is that cursed energy users who aren't registered aren't graded either. The Tokyo Jujutsu High student was expelled from the school, so she is no longer regarded as a registered Jujutsu sorcerer. Because they are rejected by the Jujutsu community, even those who are suspended or expelled from the practice are not graded.
When Maki and Toji are completely excluded from the scale, it is challenging to determine whether they could be classified as Special Grades. Maki and Toji are unable to control cursed energy, unlike jujutsu sorcerers, who are born with this ability. Both can use cursed weapons, but neither has a cursed skill or can work with cursed energy. Therefore, they cannot be directly categorized as sorcerers or evaluated using the same criteria.
Toji and Maki are Subject to Heavenly Restraints
Toji and Maki made Heavenly Restrictions in exchange for their extreme physical prowess because they were born with cursed energy levels comparable to a regular civilian. This kind of cursed restriction affects the cursed energy of the person in exchange for restrictions or advancements. These are bindings that are put on a person's body at birth to give them access to enhanced abilities. They made the sorcerers who were born with low cursed energy physically gifted in Maki's and Toji's cases.
Jujutsu sorcerers fall into a different category than Heavenly Restricted people, such as the disgraced Zenins, and as such do not share the same ranks. The pair would not be considered Special Grades even if they submitted an application. Toji and Maki do not meet the criteria listed in JJK Chapter 205, "Stars and Oil," which are needed to be a Special Grade sorcerer. The sorcerer's expansion technique must produce a significant amount of cursed energy in order to meet Jujutsu High's requirements for the grade.
A Domain Expansion, much less one with high output of cursed energy, is not possible because neither Zenin has high levels of cursed energy in accordance with their Heavenly Restrictions. Despite being formidable opponents in their own right, Toji Fushiguro and Maki Zenin do not meet the requirements for Special Grade Jujutsu sorcerers.