Well, as Mikoto doesn't seem to be powering up towards becoming lightning incarnate, I don't think she's doing much resisting. There's also the juxaposition of her not lying flat, which increases the visual cue of being powerless and the fact that Kuroko is looking not at Mikoto but at the viewer, which reduces the threatening effect that would be present were she focused more on overpowering the "victim". So no, I don't think this needs that tag.