Man this is a hard one. Both sculpts are sheer quality! They both have the lace thing going on, they both have a similar expression and face (Manriki's head could be a tortle head with a mask on), and they both have great characteristics that set them far apart from other figures. I mean Snigator is a Turtle here! And the Manriki has Clamps for shoulder blades!
I find these 2 sculpts to be almost equal! in the end it comes down to taste for me. I like Turtles alot....in fact I watched the very first Gammera movie today.
I'm gonna vote 22. I've always liked this figure. I had 204 when I was a kid, but can't recall if I had 22. 204 always lost fights. Mainly because he would always get knocked on his back and dry out in the sun.

He didn't have rocket propulsion to fix that problem like Gammera.
22 doesn't need his arms. All he has to do is lean forward and clamp onto the competition. He could probably even crack this turtles shell.