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AFAIK, a buffer overflow is achieved by overwriting memory adjacent to a C variable’s buffer. This overwriting is used to spawn a shell which executes commands.
But what if the user that is running the program vulnerable to a buffer overflow has the shell disabled ?
/etc/passwd:
user1:x:1000:1000:user1,,,,:/home/user1:/bin/false
sudo -u user1 /usr/bin/programname
“Shell disabled” only matters if you’re actually logging in. If you’re exploiting an already running program then you don’t need to log in.