Surface reconstruction from cross-sectional data is important in a variety of applications. It is usually possible to generate a surface in many ways, but only reasonable ones are acceptable. A surface of minimal area has been considered as one of the most natural optimal criteria for the original tiling method of surface reconstruction from cross sections. In the paper, we consider minimal surfaces for continuous generalization of the tiling approach and in the general situation of reconstruction from cross sections. We show that in these cases the minimal area criterion leads to defective surfaces and is thus unacceptable.