1989s Batman retroactively gained a new villain, thanks to John Jackson Millers Batman: Resurrection, and we already know what becomes of this antagonist. Set between 1989s Batman and Batman Returns, Resurrection explores the fallout of Jokers lethal crime wave in the first film while setting up the rise of Returns villains like Max Shreck and The Penguin. Additionally, Resurrection introduces Basil Karlo Clayface to its Burton Batman universe and retroactively adds Hugo Strange who serves as the books true villain to 1989s Batman as a background character.

https://screenrant.com/batman-resurrection-hugo-strange-future-echoes-explained/