It depends a bit on the situation. When I had a girl who would have seriously fought with other girls in the house, it required much stricter management than dogs who will get into a scuffle in certain circumstances. For the former, we always had at least two barriers between her and the other girls. That meant for a C&R failure to occur, at least two things had to go wrong. Usually there was a baby gate at the top of the steps and a door at the bottom. It could be though a crate, door and babygate or any other combination. But for safety sake, there had to be at least two barriers and one of those two barriers had to be something pretty solid (pretty much a door). She would violently fight with the other girls when given a chance and it was dangerous to her, them and us.
OTOH I had two girls who would get into superficial scuffles in the house when they got into each others space. All that was required there when someone was home was a baby gate in the hallway to keep them out of each other's way.