With a simple test case I get a validation error of: document type does not allow element "style" here.
This is with an empty XHTML Strict document with a style element inside a noscript element. The noscript is inside the body.
To clear up the validation issue:
noscript is only allowed in the
style only allowed in the
head. Therefore, the latter is not allowed within the former.
On the general issue: you'll want to make the