Black Canary doesn't seem to use her scream all the time and during Manhunt, the threesome Black Canary, Huntress and Catwoman were not confident in facing Lady Shiva at the end and hightailed it. Batgirl has bested Lady Shiva once. Also, Batgirl was one of the people she confronted to help her (Black Canary) in her rehabilitation. Batgirl should win this fight.
