Ziva David Could Bring Leroy Jethro Gibbs Back To NCIS
Ncis history suggests that Ziva David could pull Leroy Jethro Gibbs out of retirement. Gibbs hasn't been seen in the franchise since Mark Harmon's character retired from the Major Case Response Team (MCRT) in NCIS season 19.
Ziva was the one who pulled Gibbs out of Retirement in Ncis season 4. In the season 4 premiere, "Shalom," Ziva was framed for the death of a Syrian colonel and two FBI agents. She turned to Gibbs for help, and he came out of retirement to help her clear her name.
Gibbs and Ziva have a unique relationship. She saved his life in season 3, episode 2, "Kill Ari Part II," and he has protected her at all costs ever since.
The Tony & Ziva spinoff would be the ideal platform for Mark Harmon's NCIS return. It would suggest that Gibbs is returning to help an old friend, rather than introducing him back to the main series and implying that he is needed for the new MCRT to function.
A request from Ziva would be a believable way for Harmon to return, and it's less involved for both the character and the actor.