[QUOTE=Solomon;50977422]does robin's outfit with graffiti implying he's dead not count[/QUOTE]
[img]http://img.cinemablend.com/cb/3/6/7/d/d/e/367ddedb51533e3c1059ec33195120ff02aaf0a2677fb57fddafafeafa46c8ea.jpg[/img]
I'm going to go ahead and say it was probably Jason Todd as well, since he was killed by Joker in Death in the Family.
[QUOTE=Solomon;50977422]does robin's outfit with graffiti implying he's dead not count[/QUOTE]
Going by how the comics and any other medium treated the aftermath of Todd's death that event did not lead up to him intentionally killing anyone.
The only time he intentionally/without thought kills someone is during The Dark Knight Returns which, even as a contained story, built towards the moment believably and the act itself helped to make the final act of Returns even more impactful. TDKR relied on the prior legacy of Batman as well as the events within the comic to justify that exact moment.
Batman randomly killing people with a slight hint at a past event is hardly a solid justification of him dropping his code. You can argue that's "show don't tell" but that specific element hardly shows much other than where the timeline might be. They didn't do a solo Batman film before this, therefore it should be assumed that they want people to view him based off his well-established legacy and therefore the golden rule would be the first thing people have in mind.
I don't see how Batman's hatred for Joker could contribute to him just killing random thugs or mercs. Joker is a very specific and special case with absolutely no chance of rehab whereas Batman has stated multiple times that he believes everyone (sans Joker) can be helped or saved.
And yes people can pull up Final Crisis or his very earliest incarnation but the fact is if the movie is just throwing us into the situation as it did, then it must be assumed they are working off of his most famous incarnations all of which adhere to the no kill rule.
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