I think it depends, I have seen it work eather way. We had a very aggressive desert tortoise that would head bob, ram, and bite all the other tortoises and he would bed down in the other tortoises dens solely out of trying to bully the other one out and make them leave. Once those tortoises left to a different den he would then go do the same thing over again. With the case of these two I do not see the aggression as you can see from the picture they have their heads and legs stretched out in a sign of comfort and trust. They were so dosile that I found myself giving the cage a shake as to make sure they were both still alive (we are all guilty of this a time or two lol).
