There needs be no disparity in strength, in an applied pin. For even when rivals are equal, such a hold can be a prison for them both. Minutes or even hours may pass when two women locked together in such a hold, when neither is willing to release or relent. It is one of a few holds that can be a risk to both competitors, as either might fully exhaust their reserves, and leave themselves open for their rival to take control of the bout. In addition to the risk of exhausting oneself, there is an even greater threat that the woman on bottom might be resting and regaining their reserves, allowing the woman applying the pin to do all the work, whilst they bide their time.
And thus, apart from wrestling done in a ring, with a referee planning to count to three when shoulders are pinned, there is little justification for such a hold, as it is only effective if one can hold it until their opponent literally gives up from either fatigue, or frustration – or if it used as a prelude to a kiss, and a turn from a battle of biceps to womanhoods.