[quote=@NRVNQSR]
In Nasu mechanics, probably not. Gilgamesh can defeat earth mother goddesses which are leagues above regular divine spirits.
[/quote]
Speaking of which, isn't it true that the Holy Grail can't summon divine spirits like Michael? Kyubey's Holy Grail, despite being artificial, is manufactured after the design of the destroyed Holy Grail, so the rules are almost the same.