I agree with @Koays: on a lot of points he made. The hierarchy of telepathy isn't static, it changes over time with how the characters themselves grow and the preferences of the writers in charge at that point.
I think he mentioned in this thread (one maybe one of other 50 telepathy battle threads, you guys need to slow down), that Revolution and New Xmen (in addition, Seagle and Kellys run), were what pushed Jean as a top Telepath, but since then, other Telepaths have grown In power and changed. Xavier got stronger in Legacy and may be even more stronger after thousands of years battling on the astral plane. But I think Jean is still portrayed as being stronger than Emma, Rachel and Betsy.
My reasons being Cassandra Novas comment on Rachel being weaker than Jean in the Xmen Red annual, and Rachel being taken out by psychic projections from Jean in Phoenix Resurrection. Then there's Jean as a ghost getting past Emmas defenses, and possessing her body and keeping her from actively fighting back as teen Jean searches her mind. Backed up by her feat in Phoenix Resurrection where she is Subconsciously projecting psychic manifestations at different locations around the world and on the moon, projections that could take on teams of Xmen and led to 3 Telepaths (cable using Cerebra, Rachel and Psylocke) being taken out, I'd consider her among the top 5 Telepaths right after Shadow King, Xavier, Cassandra, with Exodus coming up right behind.
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