Where to place your h1 tags?

The only place that the HTML title tag is valid, according to the W3C, is inside the section of the document. So the

Content

It doesn't matter if the title comes first or last, or mixed in with other head tags like script or meta, but it *has* to be in the head. In XHTML and HTML5 this tag is required for the document to be valid.

I usually place the tags above my tag, sometimes in the section if I use that.