X-23's appearance in X-men did not completely impress me to make her a contender with Batgirl, but her own X-23 series showed her to be a terribly skilled and ruthless fighter/killer, even as a kid. With a healing factor that could help her null disabling attacks and the beserker rage that [at least in Wolverine's case] has shown to be trouble for precogs and other mind/body reader types, I give X-23 the advantage.