Of course it equals strenght. Any increase in any muscle equals strength. It's all simply relative to what you're training for. If you're only interested in power lifting, then it might not help all that much, but people train for different reasons. I get what you're saying though; if all somebody does is curls, they're not going to be as well-rounded strength-wise as somebody who focuses on complex movements.
I guess it may also be because we have no way to test strength in just the bicep.
To much variation goes into the lift person to person.
Leverage and forearm length are all factors.
Do you fully extended do you contract to the absolute fullest.
Also people with massive biceps usually have figured out how to activate the muscle properly.
They usually have in depth understanding of their biceps needs to cause growth.
Which again varies wildly person to person.
But an example off the top of my head is Ben Pollack vs Ronnie Coleman.
Who do you think is stronger?
Again our mechanisms for gauging strength are limited
According to Rippetoe;
The guy who lifts 401 is stronger than the guy that lifts 400.
Even if the guy who lifts 401lb weighs 300lb and the guy who lifts 400lb weighs 200lb.:
So pro body builders, who have huge development of muscle throughout their whole bodies normally do not have lifts that pro power lifters have.
Even pro power lifters that are 50lbs lighter.
So I disagree that a bigger muscle ALWAYS equals a stronger muscle.
At some point the trickery and confusion used to cause that extra growth ends up with a bigger but weaker muscle.
That leads me back to the mind muscle connection.
Ronnie Coleman MUST have an intimate connection with his mind and his muscles.
I mean look at his back!!!
Again I'm a fan of big peaked biceps....but I don't think it comes with more strength always.