Board Thread:Questions and Answers/@comment-6296810-20140622193753/@comment-5398287-20140622203446

Now that I think about it, there HAS been one instance of Zanpakuto "stealing" in the series: during the Deicide arc, Keigo nicks Zennosuke's Zanpakuto to defend himself, as Zennosuke was unconscious at the time. Zennosuke had to physically track Keigo down and take his sword back, so that seems to prove that he can't make a new one, call it back at will, etc. etc.