Thanks to Frieza, Perfect Cell wouldn’t be too weak to fight Goku and his friends if he somehow returned to the Dragon Ball anime. Though Cell has been dead for more than ten in-universe years, there have long been theories that the franchise will one day bring back the character. However, there’s a massive gap between Cell’s power level in Dragon Ball Z and where the Z-Warriors are now.
Much has changed since that day when Gohan discovered the Super Saiyan 2 transformation and annihilated Cell with a Kamehameha. Though there was a time when Cell was Earth’s biggest threat, several Z-Warriors have eclipsed him at this point in the franchise. In addition to Gohan, Goku, Vegeta, Gotenks, Android 17, Majin Buu, and Piccolo are all at a significantly higher level of power. An argument could even be made that weaker heroes like Krillin and Tien might be able to match up with him by the end of Dragon Ball Super. That being said, Cell is still a favorite to return either as Dragon Ball Super: Super Hero’s secret villain or as the main antagonist of a future saga.
While it’s true that Cell isn’t in the same league as the Z-Warriors anymore, what happened to Frieza in Dragon Ball Super proves just how little that truly matters. Upon his resurrection, Frieza made some shocking gains by unlocking his golden form and catching up to Goku and Vegeta, which he was able to do in just four months of intense training. How he quickly acquired power that Goku and Vegeta spent years trying to attain speaks volumes about his innate physical capabilities. It seems members of Frieza’s race possess a unique ability to rapidly increase his power. Since Cell shares his DNA, he should have what it takes to reap the same rewards and once again become a powerful adversary of Goku and the others.
It's important to note that Goku, Vegeta, and Piccolo aren’t the only ones whose genetic material was used to create Cell. It was established in Dragon Ball Z that Dr. Gero also implemented the DNA of both Frieza and his father, King Cold. Presumably, it was recovered by the Red Ribbon Army after their deaths at the hands of Future Trunks. Because of this, Cell has access to many of Frieza’s powers, such as the Death Beam. It makes sense that this includes Frieza’s in-born ability to get stronger at an incredibly fast pace. All things considered, Dragon Ball has an easy way of immediately making Cell a threat again.
Even if he only had a few months to prepare, he too should be capable of getting back on Goku's level in Dragon Ball’s future. If that were to happen, he’d have the means of seeking revenge on Gohan and forcing his enemies into achieving new forms to beat him. The distance the Z-Warriors have created between themselves and Cell over the last several years can easily be narrowed if he were to be resurrected. Since that’s the case, Cell should always be on the table for future Dragon Ball stories.