I don't really think it is, I think it can turn into bullying depending on the way you deal with it afterwards.
Honestly though people don't like being called out for when they do shady so instead of being like "yea I'm sorry for all the shady I did" and owning up to it they want to play victim instead and be like "this is bullying, what i did was justified because of x, y and z" ya know?
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