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Pell was never actually confirmed to still be alive in-person in the manga, he's implied to be. It shows some panels of someone leaving a hospital and forgetting their hat, which looks like Pell's, implying he survived the explosion.
It's only in an anime-exclusive scene where he's shown to have actually survived as he's seen visiting his "grave".
And yes, Oda had a rule for the longest time about not killing off any developed characters. Of course that's no longer the case anymore.
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