With Site Management enabled, end-users can create their own subsite(s).
In a normal situation the administrator of the Office 365 SharePoint Online environment don't have access to the subsite(s) created by the end-user. So the end-user must first grant the Administrator owner right to the subsite(s) before the Administrator can delete the subsite(s) from SharePoint Online.
I would be practical that the same end-user can also remove these subsite(s).
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