Board Thread:General Discussion/@comment-24815992-20140416181431/@comment-4957813-20140416182603

You misunderstand, the title of Kenpachi and its captaincy goes to the strongest SHINIGAMI. Nnoitra wasn't a Shinigami, he was an Arrancar. Also, 200 members of the squad need to witness the fight, which wasn't possible. So no, it would not have been possible for that to happen.