The last we saw of Penguin in Gotham, he was passed out after being touched by Fish Mooney.
The return of his arch-nemesis from Season 1 is bound to play a large part in Season 3. Penguin/Oswald Cobblepot will really need to up his game, and according to Robin Lord Taylor, that is exactly what he plans to do.
In comments reported by Pure Break, Taylor said:
Oswald will try to be the most powerful man he can be. He learned so much in Season 2. Now he has the means and knowledge, he knows what it is to be the king of Gotham and how difficult it is. On the death of his mother, Nygma told him, ‘You’re free to do whatever you want now. To love someone is to be weak, vulnerable.’ Now he can be as ruthless as he wants. I think he will take that advice.
Gotham returns this fall on Fox.SuperFable