The first time these two guys fought, Batman was fighting as Bruce Wayne – without the armor, weapons and was even holding back since he was around civilians, and fighting all out might blow his cover. Here, despite being tortured around the Labyrinth for 8 days, Batman easily dispatches the Talon. Brutalizing him so far that the Court of Owls even decided not to bring him back to life. As one of their members said:
We should dispose of him.
Wait! But the investment in him… And he’ll heal if you give him–
Not truly, he won’t. Not in the important way. Not from that beating.
Think about that for second. Batman dished out such a heavy beating to an undead, that bringing it back won’t restore it to it’s full fighting potential.
From – Batman Vol. 2 #6