My advice to him was that having the h1 tags around images doesn't turn them or their alt tags into proper headers. A text reader will still read the image as an image, and a web crawler won't find the h1 text it's looking for.
Then I had a tiny doubt. I thought it conceivable that an "alt" tag for an image inside an h tag could inherit status from its position. But it doesn't does it? Can anyone confirm what I told him?
Example:
<h2><img src="foo.jpg" alt="A great big foo." width="40px" height="40px" /></h2>
-Hugh Todd
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