Defeat at Manchester United on Saturday leaves Thomas Frank's side 15th in the table and only six points above the relegation zone.
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"You'd have to say they are (in a relegation battle) with their current form," said the ex-United striker on The Wayne Rooney Show.
"West Ham have been in form, Nottingham Forest pick up results here and there.
"You can't think that they're not in a relegation battle where they are. I think they'll definitely be looking over their shoulders."
On Cristian Romero's red card, Rooney added: "I can see why it's been given but I think it's a little bit harsh.
"Sometimes you lose your head at times. And I think he's done that throughout his time at Tottenham."