Develop on 4.2, set min required SDK to 2.3, with a little care not to use older APIs that won't work. Android Lint should help.
And, to make it adaptable for all the versions, you will have to patch up some kind of compatibility codes here and there. That should work without any problems.
Theme: There's a nice tutorial how to handle this. http://android-developers.blogspot.in/2012_11_01_archive.html
Basically, you will need to create your own theme, and extend from the corresponding themes, depending on the SDK version (ex, Theme for 2.3 and less, and Theme.Holo for 3.0 and higher), and then you can customize your theme.