I can see "upskirt" shots not being predominantly sexual and used in a manner to show the character getting embarrassed similar to how someone gets dacked (pants pulled down in public). It's an incredibly fine line though and even the most purest intentions of making it only an embarrassing moment, not a sexual one, will probably always be questioned due to the nature of how upskirt shots happen.

I feel as though the context that triggered this discussion is important. The character clearly has had a massive dick/fat pussy bulge drawn so from my pov there is no question what is going on there... it was created for sexual purposes.