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That is not necessarily true. Yes, women are generally weaker than men, but individual variation means a woman can be stronger than a man.
Aside from that, the difference in strength doesn't matter that much- no matter how much my mom hit me, I never really had the desire to hit her back. Even when I was a teenager and could have wrecked her, I didn't want to. Then on top of that, there's the very real problem of authorities getting involved, they're going to assume the male is the aggressor, really limits your available options...
It was the same for my dad. I still remember their last fight before the divorce. They were cleaning up after dinner, and my dad dropped the ice cube tray, scattering ice across the floor. This set my mom off and she started screaming at him about how worthless he was, and she tried to kick him in the gut. He caught her foot, purely out of self defense, but that threw her off balance and she fell on the cat dishes, which led to some pretty gnarly bruising... I didn't see the whole fight, I was upstairs, but I heard it going on and came down just in time to see my mom sitting on the floor (sobbing, like she hadn't started the whole thing) and my dad standing there with a look of "I can't take this anymore"
Anywho, the point of all that was, it's not about physical strength - an abuser has a meanness that their victim(s) lack, and that matters far more.