Well, the issue is that you gained XP from them, however, if they gained a level, then they would be techically a new monster, since their CR would have gone up.TarkisFlux wrote:CR limit seems like it would have issues with recurring villains...
So when the evil wizard returns in a few adventures, he'd have gained a couple levels, and thus you could get XP from him again since he's a new monster.
Also DMs could always make exceptions for recurring villains too, even if their CR doesn't change. Mainly the XP rule is there to say that if you beat up a bunch of goblins and keep them in chains so you can beat them up to charge your bar, it doesn't work.