In order to be an effective pro-wrestler, one must perfect the art of the sell.
This is when a pro-wrestler conveys the impact of whatever move they have just taken. For example, when a wrestler throws a punch, it is imperative that the other wrestler stomp their foot at the moment just prior to impact to suspend people's disbelief and make it sound like they're actually being punched. Furthermore, "selling" is also a longer-term thing that wrestlers do over the course of a match, like spending the remainder of a bout limping after being locked in a Sharpshooter.
Sometimes, wrestlers just won't sell at all.
This can be for one of a few reasons - one is that the spot was pre-planned (either by the wrestler[s] themselves or producers) to put somebody over as an unkillable threat, and the other is that... well, the wrestler's just not all that great at wrestling. But regardless of the reason, just about every no-sell is memorable, as they're considered something of an anomaly. Of course, they're nowhere near as rare nowadays as they were, say, 30 years ago, but nevertheless, they seem to stick in the minds of fans.
And these ten no-sells, though they're certainly not the only examples from pro-wrestling's long and storied history, are most-often cited as particularly egregious...
10. Shawn Michaels No-Sells Orton's Punt
A more recent entry and a rare miss from one of pro wrestling's most gifted sell artists of all time, Shawn Michaels' no-sell of Randy Orton's Punt in the build-up to this year's SummerSlam was nothing short of unheard of.
Hypothetically, punting somebody directly in the side of their head should be enough to easily knock them out, and such has been the case for every wrestler who has ever taken The Viper's boot to their temple. For Shawn Michaels, however, this was not the case.
It was bad enough that Michaels was already stirring immediately after taking the move, but within 30 seconds, he'd already crawled his way over to the corner of the ring and began making his way up to his feet. In his defense, he never fully stood up before the episode ended, but given the devastating nature of the move, he should have been rendered entirely immobile.
Although the Heartbreak Kid has not wrestled in over a decade (Crown Jewel 2018 never happened), nobody should be so rusty as to completely forget to sell somebody's offense properly. Especially when you're promoting a World Championship match at a Big Four PPV, and even more especially when you're Shawn-bloody-Michaels, inarguably one of the all-around greatest to ever lace up a pair of wrestling boots.