You could, but using containers requires that your kernel directly provide and secure Android-compatible functionality, such as binder. A VM gives you more options for abstracting that functionality.
If you expect to be "essentially android, but a little different", containers make sense. If you want to build an entirely different mobile OS, but provide Android compatibility, I think a VM is much more likely to give you the flexibility to not defer to Android design decisions.
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You could, but using containers requires that your kernel directly provide and secure Android-compatible functionality, such as binder. A VM gives you more options for abstracting that functionality.
If you expect to be "essentially android, but a little different", containers make sense. If you want to build an entirely different mobile OS, but provide Android compatibility, I think a VM is much more likely to give you the flexibility to not defer to Android design decisions.