Noting a statement concerning Maiar-orcs:
Quote:
'In any case is it likely or possible that even the least of the Maiar would become Orcs? Yes: (...) The least could have been primitive (and much more powerful and perilous) Orcs; but by practising when embodied procreation they would (cf Melian) [become] more and more earthbound, unable to return to spirit state (even demon form), until released by death (killing), and they would dwindle in force. (...)'
JRRT, Myths Transformed, Text VIII
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In
Osanwe-kenta (probably dates 1959-60), Pengolodh notes that though in origin a 'self-arraying', it may tend to approach the state of incarnation:
'... especially with the lesser members of that order (the Maiar).' Pengolodh also cites the opinion that
'... if a spirit (that is, one of those not embodied by creation) uses a hroa for the furtherance of its personal purposes, or (still more) for the enjoyment of bodily faculties, it finds it increasingly difficult to operate wihout the hroa.'
The note goes on to describe the things that are 'binding', mentions Melian, and notes that Melkor alone among the Great became at last bound to a bodily form. And...
Quote:
'So it was with even some of his greatest servants, as in these later days we see: they became wedded to the forms of their evil deeds, and if these bodies were taken away from them or destroyed, they were nullified, until they had rebuilt a semblance of their former habitations, with which they could continue the evil courses in which they had become fixed [Pengolodh here evidentally refers to Sauron in particular...'
JRRT, Osanwe-kenta, Vinyar Tengwar 39
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If I recall correctly, after more than 400 years of the Sun the battle of Huan and Wolf-sauron takes place, and no matter what the magic art of shape-shifting entails in detail (for myself, I prefer not to cut this particular ball open too much to investigate its bounce), it's said that Sauron:
'... could not elude the grip of Huan without forsaking his body utterly.' Noting too that Sauron
yielded to Luthien as well.
As far as this hair needs to be split anyway, Sauron can be killed; and perhaps at the point in the battle with Huan Sauron's 'clothes' have become too much like an incarnate body, while by comparison Ulmo's form is more like raiment (noting again that only Melkor of the Great became bound to a physical body).