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The Cat Came Back ...
Selina's stint on the right side of the law came to an abrupt end at the hands of The Joker. Kidnapping Selina in Detective Comics 569 the Clown Prince of Crime handed her over to brainwashing expert Dr. Moon in the following issue with unpleasant results for Selina's mental state.
The Joker should have heeded Dr. Moon's advice, in her confused state Selina's mind seized on a "cat" related item she had seen in the newspaper and named a millionaire with a catatonic daughter as Batman. Unaware of this but figuring The Joker would be trying to make Selina commit a cat crime Batman picked the most likely candidate which was of course the man she had named as Batman. Unlikely, you say? Hey, this is comicbooks! Coincidences are not only allowed but expected!
As you just saw Selina hadn't turned totally to the Dark Side but she was reverting to the Queen of Cat Crimes. Figuring The Joker was a liabilty she made her own escape before Batman could catch her and get her into deprogramming. Which really ticked off the Caped Crusader.
On the bright side The Joker's joy buzzer had inadvertantly awakened the sleeping beauty after Selina saved her so at least some good came of it. Batman vowed to restore her and that's how things stood when the continuity changed. Post-Crisis none of this happened and Selina's relationship with Batman has always been more adversarial from day one. If this made her an assertive nineties woman or just another clawed loon in spandex I'll leave to the readers' judgement.
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