Stainless Steel tubing eh? That sounds like a great idea - what is the stuff they used on the original ladder? Is that SS Tubing?
I can get some pretty big SS tubing bent in the big C shape by someone - I will find someone.
I think the bottom part can bolt right up to the original holes and bolts - the top - not so much. The top will require some tricks.
I will need to figure out how to connect the top. - I need to go out into the boat and make some measurements.
Once a good brace is in place creating an unobstructed access to the rear it's anybody's game what the ladder looks like - you could use a solid ladder door that swings up so people can't walk in when the ladder is up, or re-use the original on a hinge - or recreate a completely new one - the possibilities are endless . . .
In regards to the stability of using tube - I really son't think torsioning is a big deal in that area - so if the tube TWISTS it would not be a big problem - it's really gonna depend on the strength of those bends - will the bends hold firm or will they give a little (or worse - give a LOT).
Steel plates welded with gussets and brackets are stronger but I like the idea of using tube - it has a better appearance.