The inode_init_owner function in fs/inode.c in the Linux kernel through 3.16 allows local users to create files with an unintended group ownership, in a scenario where a directory is SGID to a certain group and is writable by a user who is not a member of that group. Here, the non-member can trigger creation of a plain file whose group ownership is that group. The intended behavior was that the non-member can trigger creation of a directory (but not a plain file) whose group ownership is that group. The non-member can escalate privileges by making the plain file executable and SGID.
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