Doctor Who: 10 Things You Didn't Know About The Toymaker
2. He's Only The Third Hartnell-Era Villain To Return
Of all the strange, strange creatures in the first era of Doctor Who, only the Daleks and the Cybermen have come back in the modern era. This means that the Toymaker is in very good company, and could even take his place among those top-tier baddies as a recurring villain in the new era.
It's interesting to ponder why so many First Doctor villains haven't come back, especially as Russell T Davies' first Doctor Who era brought back the bloody Macra! The Sensorites and Drahvins have been name-checked since 2005, but they've never actually appeared onscreen.
One possible reason is that a lot of Hartnell villains were historical characters, due to the show's early commitment to educating as well as entertaining. Another possibility is that RTD and his successors (who are also now his predecessors, timey-wimey) felt that monsters like the Zarbi, the Monoids, or the Voord wouldn't work in modern Doctor Who.
The cowards!