Horde encounters are Wild pokemon only, 2v2s and 3v3s only happen against other trainers (except in Gen VII where pokemon can cry for help and turn the battle into a 2v1), so I didn't take those into account (even then, I'm trying to maximize the amount of lions defeated per move, so it would be a waste to use a multi-target move and kill 3 lions, then waste the PP of the other pokemon(s) when their move fails since there is no target to hit iirc) because in my example, PKMN Trainer Vazqueztion is using the perfect [Origin Form] Giratina to fight as many lions as they can until Giratina faints.
If the lions were able to get scared and run away, then any pokemon with intimidate would be "safe" and any pokemon with Arena Trap or Shadow Tag would be able to prevent the pokemon from escaping.
another thing, there's multiple conditions where struggle doesn't cause recoil damage, like in stadium, knocking your opponent out doesn't cause the user recoil damage
or attacking substitutes
That's why I said "main pokemon game", Stadium doesn't count in my example. Also, the lions are normal lions so they don't get access to Substitute.