You are making the basic assumption that those who are doing it are in fact submissive at all. By the very fact that they are Topping from the Bottom it is clear that they are not submissive - or at least, not yet fully comfortable in their submission to truly give up control.

All the above info about it is true... I would also like to emphasise a point made above by adding that generally Topping from the Bottom only occurs *during* a scene - not before or after it. By this I mean that negotiations about limits before a session and feedback given to a Dom/me after it is over are not usually considered to be Topping from the Bottom. I would also say that, in general, telling a Dom/me that you really like something is not in any way a guarantee that the Dom will perform this action on you and therefore is also not Topping from the Bottom.

So, the issue is manipulating a Dom/me while they are 'in character' and carrying out a session. For some, of course, a 'session' is an hour long play session with discussion before and after while for others 'a session' could be a full 24/7 TPE relationship, with all variants in between.

Now, one thing that does need clarifying... how do you distinguish between a manipulative sub trying to Top from the Bottom and a Bratty sub just being cheeky to get the punishment?