Given two arbitrary elliptic orbits around an ideal single point mass, there will always exist a transfer with the minimal $\Delta v$ required.
It's easy to find an upper bound for this ideal transfer:
$$\Delta v \leq \sqrt{\frac{2}{r_{P1}}} - v_{P1} + \sqrt{\frac{2}{r_{P2}}} - v_{P2}$$
This is a general bi-elliptical transfer, and it's sometimes not possible to do better than that.
It sets a maximum $\Delta v$ required for arbitrary transfers. Are there any trivial lower bounds for the minimal $\Delta v$ required?