User:SOTO/Forum Archive/The Panopticon/@comment-24894325-20160909213807/@comment-26845762-20160910013406
That's a bit subjective. Everyone can agree that these images of past doctors are completely new drawings. However, I find it hard to believe that everyone will have the same vision of what the comic would look like as a TV episode.
Take the recent Eleventh Doctor comics. In multiple stories, the Doctor's timeline is attacked and many of his other incarnations are seen melting out of his body. This effect could be done on TV using a combination of archive footage and CGI, but it could also just as easily be done with just CGI.
On the other hand, The World Shapers has exactly what you're talking about. It features two flashbacks to the events of The Keys of Marinus and The Invasion. In both cases, the artist tries to emulate the original scenes on paper. I would say this is one of the few comic stories which would undoubtedly use archive footage if adapted to TV, but I would still argue that the First and Second Doctors appear in The World Shapers.
This is because comics are an entirely different medium than television. If a comic reuses an image from another comic, then yes that wouldn't be an appearance. But if a comic creates something new that is meant to copy a scene from an episode, it is still creating something new.