Bojack uses this attack against Zangya, one of his henchmen. After Gohan easily kills Bido and Bujin after transforming into his Super Saiyan 2 form, Zangya steps back in fear as Gohan approaches. Bojack uses the "Dirty Criminal" attack on the surprised Zangya, killing her, and then aims the energy sphere at Gohan, who easily dodges it. Bojack proceeds to fire an energy wave at the young Saiyan, but the blast had no effect.
Appearances in games
This attack was named in Dragon Ball: Raging Blast 2 as one of Bojack's Super Attacks in his Full Power form; it is a counterattack where Bojack needs to be punched by the opponent while the technique is activated to perform the attack.