Orochimaru wins low-mid diff. No summons means no Sage Mode, and no collab techniques with Bunta. That leaves him with his base arsenal, which isn't enough for him to take out someone on Orochimaru's level, especially when all of his techs are usable without summons, and when his strongest tech is a giant 9 headed snake stronger than Manda. That's something Jiraiya isn't beating w/o Sage Mode, or summons.
how?.
i wanted to restrict Hydra too. i guess it doesnt classify as a summon because Orochimaru is Hydra.
his true form is also restricted. ill update the OT