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We are told in a Deathly Hallows flashback (actually a telepathic vision of a mind reading of a flashback...) that Grindelwald stole the Elder Wand from Gregorovitch, shooting a spell at him as he escaped. How does this count as "defeating" Gregorovitch? He didn't take it from him by force, as Harry did, or by magic as Malfoy did. He just sneaked in and took it by stealth.

Could this be the reason Dumbledore was able to defeat Grindelwald, because the latter never unlocked its full power? But Dumbledore also mentioned that rumors at the time said that Grindelwald had obtained "a wand of immense power," which seems to imply that the wand's power was unusually great. Unless that was simply Grindelwald's natural level of power, sprinkled with his own boasting about having the most powerful wand in the world. In that case even though Dumbledore never defeated Gregorovitch, he defeated the wand's current holder which "earned its respect," thus becoming its Master.

Am I missing something about how the wand was transferred from Gregorovitch to Grindelwald?

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    Speculation: he got bested because he was taken by surprise and could not defend himself
    – Clockwork
    Feb 3, 2023 at 8:18

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I am not sure there is a clear canonical answer to this, but there are some clues to direct our speculation.

When Harry asked Ollivander if Draco's wand was now Harry's, the answer was "it may be." Ollivander was (almost certainly) the highest authority on wand-lore in the books, he had just examined Draco's wand and knew Harry "took it" from him, yet he couldn't be sure it had switched allegiance. So, defeating the owner is not a guaranteed way to master a wand.

I don't know of anything that says taking a wand from its owner is the only way to master the wand, although Harry seemed to think it was.

J. K. Rowling said "The Elder Wand knows no loyalty except to strength. So it’s completely unsentimental. It will only go where the power is." So it's likely that (a) the Elder Wand would switch allegiance to whomever defeated its owner and (b) it wouldn't be too fussy about the definition of "defeated" if it could tell the new owner was especially powerful.

Grindelwald was especially powerful, and he had done his homework. How else would he know where to go to find the wand? The chances are he was able to master it, and knew he could even before he stole it. Maybe one of the reasons he was smiling in the vision was because he had already sensed the wand had switched to him.

The outcome of the final duel involving the Elder Wand clearly implied that Harry had become its master. If a wand's allegiance has to pass directly from owner to owner (as Harry seemed to believe), it must have passed to Grindelwald. If it could pass by some other means, then Grindelwald might have found a way to gain it. Either way, the chances are good that Grindelwald did master the wand, and Dumbledore beat him by superior skill.

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