"CASA Approves the company SOPs, so yes, it is a specification by CASA." I disagree.
But as it appears that I'm just looking for loopholes and you're very confident of your opinion, it looks like I'm doomed.
(And for every one else, if you're aware of any PIC having been prosecuted for contravention of CAR 248, for failure to report an aircraft defect in the manner and to the persons specified by CASA, please post or PM me the details.)