What are the core issues as to the surplus in a defined benefit plan?

The core issues as to the surplus in a defined benefit plan were described by Cory J. in Schmidt v. Air Products Canada Ltd., 1994 CanLII 104 (SCC), [1994] 2 S.C.R. 611 at pp. 625-626: In the 1980s, a unique combination of conservative actuarial estimates and various economic factors caused many pension funds to accumulate large actuarial surpluses. Many employers sought to recapture this surplus by withdrawing excess monies from pension funds as an alternate source of capital, by applying surplus funds to any required contribution to the pension plan (i.e. taking a “contribution holiday”), or by claiming a proprietary right in any excess remaining upon the termination of the plan once all the employee benefits had been provided for. Employee groups have resisted such actions, claiming that the pension plans were established for their benefit, that the employers never intended or expected to recover any contributions made to the fund, and that any surplus accruing because of fortuitous economic circumstances should be paid to them when the plans are terminated.