Now that I think about it, I'm honestly not sure how it could even happen. And I mean other than the thought that the Lazarus pit might not work in Nolan's world.
Someone above said that no body was said to be found in the novelization. Well I don't think anyone would think otherwise. The train crashed and then exploded! There's not going to be a body at all to put into a Lazarus Pit, now is there. What's Ubu going to place in the pit, A bag of bones?
If he were to come back, he may be played by someone else and explained in a way that he jumped souls. Back in '05, this debate was hot. Someone had made a GIF from the film, with the train crashing and in slow motion you could see a black shadowy figure jumping out from a window of the train but that was dispelled as just wreckage from the train.