Although Zen'in Toji had been pinned in place by Kamiyado's Cursed Speech, the technique had not actually been applied to Toji directly.
Toji possessed no Cursed Energy, so Kamiyado could not directly target him with a technique.
Instead, relying purely on his own massive reserves of Cursed Energy, Kamiyado had forced the entire surrounding space into a state of being affected by Cursed Speech.
Chapter 240