Starrk was laid back because he spent the entirety of his existence prior in forced exile however, he had all the power and ability to enforce his rank. He wasn't a clout demon like Barragan, so he gets dismissed and that's just narrow minded thinking from a fan's perspective.
We've been conditioned to only accept a certain type of villain with a certain type of motivation in this genre but Starrk doesn't fit that mold. Doesn't make him a bad villain or worth getting bushed, even if it was at the hands of the future Captain Commander of the Gotei 13.