The Scarecrow is a powerful guy. He knows how to scare anyone, of course not even he can take on Batman. Scarecrow got a Sinestro ring, but that’s not enough to take out Batman. Batman has a GL ring and many more powers. Scarecrow takes a loss and drops down the ranks, but one day he’ll be back to strike terror into the hearts of many. He’s just too powerful to stay an 0-1 for his entire life….right? Batman wins.