I could see them restricting extremely low level dueling if it's not popular enough to generate fair fights. Level 1's don't tend to stay level 1 for long so unless it becomes common practice like level 9 duels you won't see a lot of equal level competitors. At such low levels even a small difference can result in a very lopsided fight, there is a much bigger difference with a level 1 fighting a level 3 than a 6 fighting an 8. Level 1s just wont really have the skill investment, if any, to fight with anyone even slightly higher than them.
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