I guessed this probably wouldn't be valid mark-up, but thought I'd give it a try anyway:
HTML Code:
<div onclick="do_something();">
	<h2><noscript><a href="go-here.html"></noscript>Foo Bar<noscript></a></noscript></h2>
	<p>Blah blah blah, yadda yadda yadda.</p>
In case it's not obvious, I wanted to make the title of the element a link on the off chance JavaScript was not enabled. It actually worked as desired in Firefox, but the W3C validator complained. (It does not like starting an element but not closing it within a <noscript> element.)

So I was just wondering if there was any "better" way to accomplish this that is valid mark-up without becoming an overly complex markup mash-up.