The Batman feature is problematic to say the least. Batman infiltrates a school for criminals as “Matches” Malone (gag) and is quickly found out. He then has to dispatch of the criminals as Batman. Conway and Kupperberg–not sure why Conway needed an assist here, there’s no heavy lifting in this issue–never explain how the criminals figured out it was Batman.
An additional problem is with the ruse itself. Why didn’t Batman just shut the school down himself? Why bother auditing the classes?
It’s silly but not terrible. The Newton art is good and there’s enough going on with Alfred and Gordon to keep the issue moving. Oddly, all of Conway’s B plots seem to involve everyone but Batman.
The Batgirl backup is actually pretty neat. She’s unconscious for the majority of the story, which is lame, but the end is great–she’s turning into a giant serpent lady.