Dahl had escaped jail, murdered two women, and abducted a third.
He was arrested in 1880 for that murder, but escaped jail.
He always manages to escape jail to antagonize the hero in a later episode.
He narrowly escaped jail as a leader of the first national postal strike.
A news cast in the last episode claims Steve's attackers have escaped jail.
They escaped jail and were allowed to continue with their holiday.
With the successful Mogadishu raid there was no more chance to escape jail.
She later escaped jail and told Penguin to build a machine, but they were again defeated.
Some tunnels are used by prisoners to escape jail.
But at least 23 others escaped jail altogether.