Not every fight can be won through pure brute strength, which is why Batman has famously come up with endless different contingency plans to break down the different characters he often interacts with, enemies and allies alike. One of the best examples of Batman's planning is when he permanently put down Lobo, despite the alien having an unstoppable healing factor.
https://screenrant.com/batman-permanently-beat-lobo-unstoppable-healing-factor/