User blog comment:DragonDude83/PE Proposal: Shredder and Ra’s al Ghul (Batman vs. TMNT)/@comment-43752982-20200130180440

I say no. While they are among some of the more heinous incarnations of each character, most of their actions are pretty standard. Do they meet the heinous standard of the work? Yes, but their actions are generally your average murder your henchmen or attempt to spread chaos.

Furthermore, while this version of Ra's is more evil than most, he doesn't stand out enough. Even Shredder, while not as vile as he is in other incarnations, is openly villainious while Ra's isn't as much. So overall, while their methods and crimes are heinous, they don't stand out enough to count.