Talk about misleading headlines...
When the Catholic Church reconstituted the English hierarchy it was very careful not to name bishops to sees claimed by the Anglicans. Hence, there is no Catholic Archbishop of London, there is an Archbishop of Westminster instead. However there is no Anglican Archbishop of London either, but only a Bishop of London. Just who is this character that the Apostolic Nuncio to Brazil has seen fit to declare schismatic?
David Bell managed to finagle episcopal consecration through Bishop Carlos Duarte Costa. He represents the Roman Catholic Society of Leo XIII and styles himself Archbishop of London. Usually the Church does not pay much attention to such episcopal pretenders but this one not only calls himself Roman Catholic but a photograph exists of him shaking hands with John Paul II. You begin to see the need to clarify the situation.
Valid but Illicit?
The phrase "valid but illicit" has been used to describe many of these episcopal vagi but I hesitate to attribute it to anyone in the curia. Usually the phrase refers to an act performed by a Catholic priest or bishop which goes against canon law and authority in the church. Thus the ordinations of the four SSPX bishops can be described as valid but illicit. The question is why would someone completely outside the Catholic Church, like David Bell, seek to have their ordinations declared valid? What possible reason could the Catholic Church have to declare such ordinations valid? Aside from reconciliation with the Catholic Church, none whatsoever.
The most famous instance in which the Catholic Church pronounced upon the validity of orders of clerics outside of its own flock was Pope Leo XIII's bull, Apostolicae Curae in which he pronounced upon the validity of Anglican orders. Even this statement was partially based upon the fact that the Church has always felt it necessary to unconditionally ordain Anglican clerics who convert. There was some feeling that a definite pronouncement on the subject would somehow either further ecumenical efforts or spur a mass conversion. It is hard to tell which. The only time the Catholic Church does not ordain clerics who convert is when dealing with members of the Eastern Orthodox Church.
This does not prevent people like David Bell from seeking this cherished "valid but illicit" status as a way to somehow validate their own activities. It betrays an almost magical conception of the faith which denies the need for orthodoxy or communion. It is a way to somehow gain the fruits of the Church without acknowledging her authority. It is a delusion.
An Orthodox View
Apostolic succession, according to the Orthodox consists of three principles. First, to be considered part of the apostolic succession, ordination must be by a bishop who can trace his lineage to the apostles. Apparently David Bell can trace his lineage to Bishop Duarte Costa, who was Catholic at one time. However, the other two principles might prove to be a little more difficult for Mr. Bell. One must be both orthodox and in full communion with the episcopacy. You cannot be a heretic and claim apostolic succession. Neither can you be alone, separated from the rest of the successors to the apostles.
It is worthwhile to note that in most Eastern Orthodox churches, Roman Catholic priests who convert are not ordained but merely vested.
What to Do?
In my own humble opinion, divorcing apostolic succession from orthodoxy of faith and the unity of communion is not wise. Practically speaking, the question of validity should not be broached unless it is in the context of reunion. Offering it as an ecumenical carrot to somehow entice people in seems to say that orthodoxy is not quite so important. Speculating upon validity when there is no intention of reunion is unwise and injurious to souls. When they knock at the door, invite them in to the feast set out for the prodigal son. Don't set the table out in the alley...
Catholic Church Refuses to Recognize David Bell as Bishop