Well, Sauron may be forever incapable of returning by his own means...
And that's the main danger behind Necromancy... As someone said this before, if men had relations with the dead, they face the danger of exposing themselves to greater evil than just mere wraiths... Maybe Sauron, the Necromancer by excelence, could communicate with them... And even posssibly take over the person treating with the dead... I think that THAT is the only way for Sauron to come back after the undoing of the One Ring...
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"In place of a Dark Lord you will have a Queen! Not dark but beatiful and terrible as the Dawn! Treacherous as the sea! Stronger than the foundations of the Earth! All shall love me and despair!"
--- Galadriel when tempted by the One Ring.
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