Page "Svatantrika" Paragraph 22

According to the Nyingma lineage, an amusing critique by Ju Mipham of Je Tsongkhapa's assertion was to argue that Je Tsongkhapa was also a Svatantrika because of the way he refutes true establishment instead of objects themselves.

Further, Ju Mipham argues that Je Tsongkhapa's approach is an excellent Svatantrika approach that leads students further but will not lead to the true ultimate until they go further.