It could, but likely will not. For telepathy to actually work, you would need some sort of transmission organ (device) and reception organ (device). There is some indication that cells or cell networks can react to external electromagnetic fields, or even em radiation (light, which is not quite the same thing but is similar), and we can detect the electromagnetic fields generated by cell activity or cell network activity by using electronic devices, so it is not impossible, at all, for some life forms to develop a transmission and reception sensitivity or capacity. It is just very unlikely. Of course, one could say the same thing about vision. However, vision does involve a much higher level of energy (the input that we detect is very energetic compared to the electromagnetic field effects of the neural system or whatever).