It made sense that this is how Jerome could return, even as his Joker-ish influence has already permeated Gotham City’s underworld.
With Jim Gordon taking on a slightly different crimestopping role when Season 3 kicks off, it’s likely the two of them could cross paths in the future.
Gotham has been cheekily solid about keeping hopes alive that Jerome, or some other form of The Joker, would return to the show, usually through pumping that signature laughter into the background of a scene.
Fans already wondered if it would happen after his shocking death, and that was before Hugo Strange came in and made villainous resurrection a regular part of the narrative.