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If I may, I'd like to add a couple of things. In Kirby and the Amazing Mirror, Kirby ends up defeating Master Hand and Crazy Hand to get the final pieces of the mirror to get to Dark Mind.
http://kirby.wikia.com/wiki/Master_Hand
It is also suggested that Master Hand and Crazy Hand are actually part of the Kirbyverse and aren't just a cameo, as Uja (an enemy from Squeak Squad) can take the form of Master Hand (though he doesn't get any of the attacks)
http://kirby.wikia.com/wiki/Uja
Master Hand isn't even the strongest boss in the game, as Dark Mind is having Master Hand work for him.
As you can tell, Kirby defeats all three. That could easily put Kirby at Universal if you wanted to count it.
http://kirby.wikia.com/wiki/Master_Hand
It is also suggested that Master Hand and Crazy Hand are actually part of the Kirbyverse and aren't just a cameo, as Uja (an enemy from Squeak Squad) can take the form of Master Hand (though he doesn't get any of the attacks)
http://kirby.wikia.com/wiki/Uja
Master Hand isn't even the strongest boss in the game, as Dark Mind is having Master Hand work for him.
As you can tell, Kirby defeats all three. That could easily put Kirby at Universal if you wanted to count it.