When data have been physically overwritten on a hard disk it is generally assumed that the previous data are no longer possible to recover. In 1996, Peter Gutmann, a respected computer scientist, presented a paper that suggested overwritten data could be recovered through the use of Scanning transmission electron microscopy. In 2001, he presented another paper on a similar topic. Substantial criticism has followed, primarily dealing with the lack of any concrete examples of significant amounts of overwritten data being recovered. To guard against this type of data recovery, he and Colin Plumb designed the Gutmann method, which is used by several disk scrubbing software packages.
Although Gutmann's theory may be correct, there's no practical evidence that overwritten data can be recovered. Moreover, there are good reasons to think that it cannot.