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Perhaps a necessity in stories which feature a RoguesGallery, since you need to find a way to keep bringing them back but have the heroes seem somewhat effectual. This was particularly true in comics in the days when UsefulNotes/TheComicsCode held sway -- the villain had to be clearly defeated at the end of each and every appearance, requiring an escape from either being PutOnAPrisonBus or [[NoOneCouldSurviveThat apparently killed]] before he could show up to vex the heroes again. Often involves TheGuardsMustBeCrazy.
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Perhaps a necessity in stories which feature a RoguesGallery, since you need to find a way to keep bringing them back but have the heroes seem somewhat effectual. This was particularly true in comics in the days when UsefulNotes/TheComicsCode MediaNotes/TheComicsCode held sway -- the villain had to be clearly defeated at the end of each and every appearance, requiring an escape from either being PutOnAPrisonBus or [[NoOneCouldSurviveThat apparently killed]] before he could show up to vex the heroes again. Often involves TheGuardsMustBeCrazy.
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* ''Fanfic/BatmanRestlessDreams'': {{Lampshaded|trope}}. When the Joker reveals that the Mad Hatter escaped Arkham Asylum again, Batman wonders why it's so easy for criminals to escape Arkham.
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* ''Franchise/MarverlCinematicUniverse'':
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