The question is, should we design applications/forms using headers or stick to spans and divs? When the world was using html to link documents, these header tags looked like the 'Table of contents'. In the new era where html is used for applications, using header tags in the orthodox fashion (i.e. h1 contains h2, h2 contains h3 ...) doesn't make sense. Or does it?
The one place where these seem to make sense is in the context of text browsers or those with CSS disabled. Are there any implications of violating the nesting order (for e.g: h2 being the top level element instead of h1)
Edit
By 'New era' I meant usage of html for interactive web applications. The notion of a header tag in a form or a mail application or a file sharing application is what I was questioning. I should avoid fancy names I guess, and I don't actually mean <h1><h2>...</h2></h1>
It is more like the content organisation in MS Word.
I did work on some W3C compliant and AA compliant web pages, if it helps. The screen readers like dolphin supernova, just read the content, I fail to recognise how they distinguish headers or I may be missing some rather important feature.