How Snoke Could Return For Star Wars Episode 9 (But Why He Shouldn't)
2. He's Not Actually Dead
Almost as soon as he'd been killed off, there were theories that he wasn't really dead. Snoke's other appearances, outside of the Throne Room, were as a projection, and so it went that this wasn't actually him either.
It's very silly, of course, but if Abrams really did want to use the character in a much bigger sense, then pulling the rug from under everyone and revealing Snoke's still alive, ready to take the fight to Rey, Kylo, and everyone else, would be the way to do it.
It's rather more unlikely than the other options, since it's an undoing of such a crucial moment for Kylo Ren (not to mention a massive 'f**k you' to The Last Jedi), but given how this franchise has seen the return of characters we saw die before now - see: Maul - then it isn't entirely out of the question. But it should be.