Karasu’s Bounty at 400,000,000 Berries

Karasu's body isn't really a body: the Tori Tori no Mi, Model: Crow turns him into a swarm of black birds, a shape no ordinary arrest can close a hand around. The plague-doctor mask cut in half across his face doubles as a loudspeaker — a man who talks through a megaphone and who, the instant things turn dangerous, stops being a single target altogether.

As commander of the Revolutionary Army's North Army, he was one of the four officers who broke the Peachbeard Pirates' raid on the Kingdom of Lulusia. On his own, he tore the swords right out of the pirates' hands in mid-air, his swarm disarming an entire crew without landing a single conventional blow, while the population itself picked up arms alongside him. He also slipped into Mary Geoise alongside Sabo, Lindbergh, and Morley during the Reverie, in a territory where an ordinary pirate or revolutionary presence would end in immediate execution — a swarm of crows, on the other hand, simply blends into the sky above the ceremony.

The 400 million on his head prices a commander built to survive capture by construction. As long as that fruit stays active, no arrest of Karasu can ever be more than a partial one: it only takes a single crow slipping free for the entire file to reopen itself, indefinitely, by definition, no matter how the rest of the swarm is handled.