To be honest, if oxygen is discovered in the atmosphere of an exoplanet, my first thought isn't 'Aha- life!' it is 'Aha- photodissociation of water'. On a planet coverd in water oxygen would be produced by the effect of light on water vapour. Hydrogen would then be lost by Jeans escape.
But on Earth this process is slower than the rate of absorption of oxygen by the crust, so without photosynthesis the oxygen produced by photodissociation would be minimal.
Waterworlds, and icy worlds like Europa, could quite likely have oxygen atmospheres. In fact O2 is present on many of the icy moons of the Solar system.
According to A. Leger a better biomarker would be ozone.
see
http://arxiv.org/ftp/astro-ph/papers/0308/0308324.pdf
There may be abiotic mechanisms to produce and retain O3 , but its detection in an exoplanetary atmosphere is likely to be an encouraging sign.The only way to have a significant amount of O3 in the atmosphere spectrum is that O2 is produced at low altitude, eg by biological photosynthesis...



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). As he mentions, A. Leger seems to think O3 is a better litmus test than O2. Beats me why … Leger still seems to be assuming photosynthesised O2 is the supply chain source, so I'm not sure what the difference is, except O3 would be at higher altitudes, unable to be interfered with by hypothesised ground-hugging reactive H, OH and HO2, and hence, perhaps easier to detect. (Many, many, many hidden assumptions, glossing over many, many, many hidden variables here).