Relying on Cleffa to stay alive is relying way to much on luck. Tyrogues, Mewtwos, ectr. can OHKO Cleffa T1 and instantly win. Cleffa survives ON A COIN FLIP, and can easily be catchered for a prize just like Minum. Minum may require energy, but he's almost always going to be run with Eelektrik, who can just get it back.