Continuity mistake: Just before Batman takes his mask off at the end, the black makeup around his eyes vanishes while the mask is still on. (01:48:20)
Batman Returns (1992)
Ending / spoiler
Directed by: Tim Burton
Starring: Christopher Walken, Michelle Pfeiffer, Danny DeVito, Michael Keaton, Michael Gough
Batman stops the kids being lured to death and beats the crap out of the Penguin who dies, while Catwoman electrocutes Max Shrek. Bruce Wayne thinks Selina Kyle is dead. Catwoman survives.
Mark Cuss
Selina Kyle: Ok, Intimidate me, bully me if it makes you feel big. I mean it's not like you can just kill me...
Max Shreck: Actually, it's a lot like that.
Trivia: Annette Bening was cast as Catwoman but after becoming pregnant was replaced by Michelle Pfeiffer.
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Answer: Nothing was stopping them. After Penguin's true nature was revealed, they most likely started searching the entire sewer system but couldn't find where his lair actually was so they had no choice but to give up.