Yes the huntsman could appear in the flashbacks in the character’s pasts, but he isn’t alive in the fairytale land. That is just a flashback before he died. It is just when they say he is alive in the fairytale land it makes it seem like he is going to be alive in the future and somehow he and Emma are going to meet again and that isn’t going to happen unless they do ghosts.
Could you please explain why you say he isn’t alive in FairyTale land? If he was alive in Storybrooke at some point, doesn’t that mean he was alive when the curse was enacted?