Shiva's never beaten Batman, whereas he has beaten her in Public Enemies. And that win counts.
-There's no evidence Shiva was under mind control, just one line of speculation from Batman
-There's no evidence her skill was impaired in any way. Batman doesn't make any mention of it.
-Even if Shiva had received a telepathic command to kill Batman, that's no reason to think it would make her fight any worse. If anything, she'd be fighting with no holds barred.
-On top of that, Batman is her equal or superior in stats across the board.
So yeah, Batman beat her. People who insist otherwise are kidding themselves.
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