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Karma's power of possession isn't exactly telepathic. It's possession. I don't think Juggernauts helmet would protect him from that.
Even that telepath Faurak who was beaten by Professor X wanted control of Karma, in NM 25 - 35.
She has one of the coolest powers there is.
One petite vietnamise girl defeats the Unstoppable Juggernaut.
Anyone she faces becomes her weapon against her foes.
She could stop Juggernaut until he was restrained by anti gravity devices of the Vault.

Karma is cool, even when she was as fat as hell. But I think possessing someone is some kind of telepathic attack, and that don't work too good against Juggs.

Karma takes control of the self. She doesn't have to get into your mind to do it. Thats why shes so frickin powerfull. She might be enough to take down Xavier.

Karma's possession is magical, not psychic, in nature. It's just like classic demon possession.