As part of a fan made comic, while officially Batman's last sighting was at the site of Two-Face's death, Batman did make several appearances, though none of those were confirmed. So, it's not too implausible to believe that Batman did put on the cowl a couple of times, but in secrecy, without the public knowing. Batman would do his thing in secret, and the public would think it was the cops.
However, out of all those, I don't think the "mafia" types like Black Mask, Ventriloquist, Penguin etc.. would work because of what happened in DK and the Dent Act. But the most likely is Riddler, maybe even Firefly or Wrath. Wrath i think is a pretty strong guess. With the police now in full force, we have an Anti-Batman who goes out of his way to kill cops. It also supports the opinion that the city and GCPD don't want "Batmen" running around anymore because they believe they end up becoming killers. This supports the GCPD's later animosity.
A battle of wits away from the public eye between Batman and Riddler could work.
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