I remember in the novel Heathcliff was referred to as being somewhat Gypsy, but not Indian or black. Gypsies often camped in southern Europe (Romania, Spain,the Basque region, etc.) Many of them, from what I've read, had that southern European or slightly Middle-Eastern look--dark hair, brown or hazel eyes, and olive skin. To English eyes, a guy who had olive skin probably seemed "dark."
Also, in the novel, Cathy's skin is referred to as being "brown," which essentially meant "tan," from being in the sun. Proper girls didn't get tan or spent time in the sun, so "dark" often just meant not the pale, lily-white English skin that was commonplace.
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