Understanding whether public-key encryption can be based on one-way functions is a fundamental open problem in cryptography. The seminal work of Impagliazzo and Rudich [STOC’89] shows that black-box constructions of public-key encryption from one-way functions are impossible. However, this impossibility result leaves open the possibility of using non-black-box techniques for achieving this goal. One of the most powerful classes of non-black-box techniques, which can be based on one-way functions (OWFs) alone, is Yao’s garbled circuit technique [FOCS’86]. As for the non-black-box power of this technique, the recent work of Döttling and Garg [CRYPTO’17] shows that the use of garbling allows us to circumvent known black-box barriers in the context of identity-based encryption. We prove that garbling of circuits that have OWF (or even random oracle) gates in them are insufficient for obtaining public-key encryption. Additionally, we show that this model also captures (non-interactive) zero-knowledge proofs for relations with OWF gates. This indicates that currently known OWF-based non-black-box techniques are perhaps insufficient for realizing public-key encryption.