harry potter - How could Dumbledore summon the House-elf Kreacher in Half-Blood Prince, Chapter 3?

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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