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One use could be where the actual page title is a graphic and the webmaster just wants to make it clear to the SEs what the heading is.
Another use could be dropping 50 of them throughout the page with the keyphrase repeated 5 times in each.
You might define the first as 'ethical' and the second as 'unethical'.
Doesn't really matter though, because the real question is 'are hidden H1 tags acceptable to search engines'.
Answer: If it's got "hidden" in the name of the tactic, it's not likely to be acceptable and it's a matter of time until the search engines tell you so with a penalty.
If they're hidden through css i would say "stinky".