There is not much difference between a .380 and a .38 special out of a snubbie.
They both can be extremely accurate. I had a Colt Lightweight Agent which would consistently put all shots, using wadcutters, into the same hole at 15 feet.
The .380 was extremely accurate. I took my test with it the same day I bought it and scored a 95 on the shooting test. I was concerned the .38 Special wouldn’t be as accurate but he’s right about it not mattering so much if somebody is close enough to be shot. It is much more accurate than I expected though.