User blog comment:Miskos3/Fairy Tail Chapter 367: Jellal vs. Oracion Seis, Review/@comment-5268982-20140117180324/@comment-7418318-20140117183409

If Sayla is "remote controlling" his body, rather than having reprogrammed his mind, so to say, it's possible that sleeping magic and knocking him unconscious won't work.

And with his physical strength, restraining him might be a bit problematic, but between Macao's purple flare, Wakaba's smoke magic, Laki's wood-make and Droy's plant magic they should still manage somehow. Levy might also be able to conjure up restraints with her solid script and Gajeel could also create iron shackles.

Yeah... even if sleep won't work, there are still plenty of other options available to the guild.