Dragon Ball Z's Android Saga and succeeding Cell Saga were turning points for the series in multiple ways. Featuring new Super Saiyan forms and deadly robotic assassins, these arcs were at one time meant to pave the way for Gohan to take center stage in the franchise. The Android Saga would also end with a heel turn for the titular technological foes, but one of them didn't make it out alive.
Android 16's battle-ready nature belied a gentle and protective instinct, but neither this nor his brief friendship with Krillin and Gohan saw him revived after Cell's defeat. Here's why the gentle giant wasn't wished back like many others killed in the Android and Cell Sagas -- and how he could eventually return in Dragon Ball Super.
Why Android 16 Is Still Dead In Dragon Ball
Android 16 was killed during the battle with Cell, with the latter being far eviler than Dr. Gero's other creations. Before the battle, 16 had become something of an ally to the Z-Fighters, especially Gohan. This was due to his love of nature and life, something he, as a purely robotic Android, was the exact opposite of. Before being destroyed for good by Cell, 16 urged Gohan to fight on, defend the planet and all the innocent life on it. The gentle android's death sent Gohan into a fit of rage and anger which he used to transform into Super Saiyan 2 and defeat Cell.
Following Cell's destruction, the Dragon Balls were used to revive those killed during the massacre of the preceding sagas. It's never explicitly stated if Android 16 is part of this number, though there's good reason to believe he's not. Androids 17 and 18 were originally humans who, like Dr. Gero himself, were merely cyborgs fitted with cybernetic parts. For instance, 18 later married Krillin and had their daughter Marron without an anatomical issue. Android 16, on the other hand, was completely robotic, and in the Dragon Ball manga, Shenron cannot revive or reconstruct purely artificial beings. This is why Android 16 is never seen or heard from again.
Ironically, the anime does show Shenron as being able to do these things when the Earth's citizens are restored after the Kid Buu Saga. This included the fully robotic Android 8, an old friend of Goku's who looked like Frankenstein's monster, as well as the robotic girl Arale from Dr. Slump. The movie The Path to Power, which retold the Red Ribbon Army Saga from the original Dragon Ball but with the updated animation of Dragon Ball GT, also showed Android 8 revived by the Dragon Balls. These discrepancies are only in the anime, however.
How Android 16 Could Still Return In Dragon Ball
Changes to the Dragon Balls' power, even in the manga, are not uncommon. Dende was brought in to replace Kami as the Guardian of Earth after the Androids began to wreak havoc, so he could have upgraded the Dragon Balls after 16's death to work on robotic beings. He may have even done so, reviving Android 16 off-screen and explaining the presence of a revived Android 8 and Arale in the anime.
This means Android 16 has just as much chance as anyone to show up again in Dragon Ball Super, living the life he had always dreamed of and maybe even fighting once again to defend the Earth against all who would threaten innocents.