>>31233684Agree that that might not the criteria, but samurott's armor is also a fucking shell in this case. If it doesn't get it is most likely because of what
>>31235075 says than anything else
I think even GF has certain confusion on when shell smash is justified. Carracosta has a super sturdy shell, case in point:
>It constructed its *sturdy* shell by crunching and swallowing the hard shells or bones of its prey.>It gets shell smash. Blastoise is a turtle with a shell too;
Can't get shell smash.
However it doesn't seem to be that the justification is "if this turtle breaks its shell it might leave its vital organs lethally exposed", since torkoal and turtonator do get shell smash and they aren't that much different from blastoise in terms of biology. Heck blastoise could even fracture the plates covering its cannons, not its entire shell, and that already could count as shell smashing.
Huntail can get it because clamperl can get it, even if it doesn't have any visible shells, unlike gorebyss that at least has its bra.
TL;DR - I think GF gives shell smash to things when they feel like it, tbqh, and if things like pupitar don't get it is because they don't want to make tyranitar an overkill.