Street Fighter 4's Seth may an extremely cheap and frustrating obstacle that keeps you from unlocking every character in the game, but Arkham Asylum ultimately wins through utter disappointment. The entire game beforehand was a well-crafted action-adventure game that made use of all its licensed characters in a way that was reverent rather than exploitative, so to end the game with such an uncreative boss battle -- against the Joker, no less -- felt like a slap in the face of Bioshock proportions. To that end, it also re-hashes the same boss battle -- Bane -- a number of times. A game that executed well on every other aspect honestly deserved better.
Runners-Up: Seth (Street Fighter 4), The Vault Boss (Borderlands)
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