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Here is the relevant text from Half-blood Prince:

"You see," Dumbledore said, turning back to Harry and again speaking as though Uncle Vernon had not uttered, "if you have indeed inherited the house, you have also inherited —" He flicked his wand for a fifth time. There was a loud crack, and a house- elf appeared, with a snout for a nose, giant bat's ears, and enormous bloodshot eyes, crouching on the Dursleys' shag carpet and covered in grimy rags.

How was he able to accomplish this? He did not 'own' Kreacher as his personal house-elf; Kreacher was not (yet) in service to Hogwarts (as Winky was at the end of Goblet of Fire).

Beyond just "because he is Dumbledore, duh", is there something else?

Is this a (relatively minor) oversight by JKR?

And instead couldn't Dumbledore have asked Harry to try to summon Kreacher instead, and use that to prove that ownership of #12 Grimmauld Place had indeed transferred to Harry from Sirius?

Thanks.

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    He doesn't seem to summon him like Harry does, he just waves his wand and makes him appear. Perhaps he had him in some form of custody already. – user46509 Apr 30 '16 at 19:51
  • @ATB: Make it an answer? – chirlu Apr 30 '16 at 20:45
  • @chirlu I don't like answering where I've nothing to back it up – user46509 Apr 30 '16 at 20:46
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    ATB, thanks, I think there may be something in the second part of your response: "Perhaps he had him in some form of custody already"--especially if you mean some sort of "legal custody." Perhaps he was the executor of Sirius' estate (since most of the Wizarding World thought Sirius was a murderer, there would be only members of the Order eligible for this, plus a few underage students). That could give some sort of temporary access to 'property,' which would include a House-elf, presumably. In the same way that Scrimgeour briefly held some of Dumbledore's possessions in Deathly Hallows. – user62159 Apr 30 '16 at 21:02
  • @ATB: No-one is going to have more than that Dumbledore uses his wand, whereas Harry summons Kreacher just by calling him. – chirlu Apr 30 '16 at 21:09
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Dumbledore was probably acting as the executor of Sirius's will, giving him temporary control over Kreacher.

This question is partly answered in the comments by user62159 but I thought I'd put some flesh on the bones.

It really comes down to the mechanics of how objects from a will are passed over from the deceased to the recipients in Harry Potter. The closest parallel we have is how Dumbledore's own will is handled. In that case the will's contents were controlled by the Ministry of Magic temporarily and handed on to Harry, Ron and Hermione at a later date. In the interim, Rufus Scrimgeour acted as the executor of Dumbledore's will.

Dumbledore didn't have a house-elf of his own so we don't see Scrimgeour handling that situation. It's likely that if Dumbledore had had an elf that Scrimgeour would have been able to summon him/her just like Dumbledore did.

The specific circumstances of Sirius's will are described as follows:

“Well, Harry,” said Dumbledore, turning toward him, “a difficulty has arisen which I hope you will be able to solve for us. By us, I mean the Order of the Phoenix. But first of all I must tell you that Sirius’s will was discovered a week ago and that he left you everything he owned.”
(Half-Blood Prince, Chapter 3, Will and Won't).

Dumbledore says that the will "was discovered" - but doesn't give any details about who had been allocated the task of executing the will. However, it seems reasonable to suppose that, since Sirius trusted Dumbledore and since it was Dumbledore who gave Harry the news that he'd inherited Sirius's house, elf and possessions, that Dumbledore had been formally allocated that task. This would just have been a temporary responsibility; he was never Kreacher's owner. Dumbledore had the ability to control and summon Kreacher whilst fulfilling his duties as the executor of the will but he couldn't keep him indefinitely. How long that temporary power lasted isn't made clear. It may well be 31 days, which is the time period that the Ministry is allowed to hold suspicious items before it has to hand them over to their new owners.

“So why have you decided to let us have our things now? Can’t think of a pretext to keep them?”
“No, it’ll be because the thirty-one days are up,” said Hermione at once. “They can’t keep the objects longer than that unless they can prove they’re dangerous. Right?”
(Deathly Hallows, Chapter 7, The Will of Albus Dumbledore).

Dumbledore is trying to establish whether, at the end of this temporary period, Kreacher will pass onto Harry, Bellatrix or someone else. But, until Kreacher did pass into new ownership, Dumbledore had the ability to summon him at will.

As for the point about Harry being able to summon Kreacher, this is correct. I suspect that the reason he was rather theatrical in summoning the filthy Kreacher into the Dursleys' spotless house is the same reason that he keeps the mead glasses bouncing off their heads repeatedly.

Harry could not suppress a suspicion that Dumbledore was rather enjoying himself.
(Half-Blood Prince, Chapter 3, Will and Won't).

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The main issue here is deciding who Kreacher belongs to. While beforehand Kreacher did belong to Sirius, he did everything grudgingly, if at all. Therefore, it wouldn't really be a good idea for Harry to summon him outright, as Kreacher could bypass this and come whenever he felt like it- tehnically, if he still came eventually, he wouldn't be disobeying. It would have been terribly annoying to sit in the Dursleys' house for a few hours/days to see if a house elf shows up or not.

As for Dumbledore being able to summon him, all I got for that is that maybe Dumbledore did manage to have some control over Kreacher in the past. House-elves will obey more than one "master", as long as they're part of the family they're serving. For example, Dobby would obey any of the Malfoys, and Kreacher would obey the painting of Mrs. Black as well as Sirius. With Dumbledore as not only Secret Keeper of Grimmauld Place, the family house, but also leader of the Order of the Phoenix, it would make sense if Kreacher obeyed him by default. Then again, one may argue that once Sirius died, this didn't matter anyway.

If Dumbledore has no "official" control over Kreacher, he probably just had him in control the way people can have control over one another. Kreacher, though mean spirited as he is, probably couldn't do much to resist a powerful wizard like Dumbledore. Honestly, when they vacated Grimmauld Place, someone probably had the sense to take Kreacher with them, as no one would want some Death Eater stumbling upon him while they were gone, even if Harry did own him. Dumbledore probably just left Kreacher somewhere and told him to wait until he summoned him, and gave him a convincing enough reason to stay put, either through threats or rationalization.

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    I think you're misunderstanding how a master summoning a house-elf works. The elf doesn't have a say. This can be seen when Harry summons Kreacher by calling his name and both Kreacher and Dobby, entangled in a vicious first fight, appear before him, not even knowing what happened. The elf just appears quite automatically—not through the elf’s own personal, voluntary magic, but through the general master/house-elf magic itself. – Janus Bahs Jacquet May 1 '16 at 4:38
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    I agree. Kreacher had no great love for Dumbledore or Harry and so wouldn't have come unless he was forced to. That's where the distinction between a command from a legitimate master (which Kreacher had to obey) and a spell or request (which, presumably, he didn't). Dumbledore flicked his wand, though what spell he used I think will remain a mystery. – The Dark Lord May 1 '16 at 13:32
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He uses his wand to flick and summon Kreacher. So it is evident he didn't control Kreacher as master, but as captor, to stop him from going to the Black sisters Cissy and Bella.

Additionally, a powerful wizard like Dumbledore, could bind him using a anti-dissaparation jinx like he did for those Death Eaters in the Death Chamber. So he could summon him whenever he wanted.

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