It has to be a supporting actor, minor character, cameo or breakout role. IE such and such stole that scene / film from the lead actor.
Agreed, otherwise it’s just: “lead actor does good job”
Having just seen The Imitation Game, I agree with Mark Strong – wanted more from him in that movie…. thought he was excellent in (his minor part in) Tinker, Tailor, Soldier, Spy too. Although he probably didn’t steal the show in that because ALL the supporting cast were excellent.
Interesting that the villains in Batman always seem to upstage the leading man. Apart from the last one – it was only really Oldman that came out of that well. Maybe batman is too inherently woody to play well?
Aha! What about: