Subscale,
AN honest question, not a criticism.
What is it which leads you to think descending below MDH is acceptable under JAR-OPS? The only bit I could find is in JAR-OPS 1 Appendix 1 to 1.430 which is pasted below;
(2) Minimum Descent Height. An
operator must ensure that the minimum descent height for a non-precision approach is not lower
than either:
(i) The OCH/OCL for the category of aeroplane; or
(ii) The system minimum.
(3) Visual Reference. A pilot may not continue an approach below MDA/MDH unless at
least one of the following visual references for the intended runway is distinctly visible and identifiable to the pilot:
(i) Elements of the approach light system;
(ii) The threshold;
(iii) The threshold markings;
(iv) The threshold lights;
(v) The threshold identification lights;
(vi) The visual glide slope indicator;
(vii) The touchdown zone or touchdown zone markings;
(viii) The touchdown zone lights;
(ix) Runway edge lights; or
(x) Other visual references accepted by the Authority.
Para (3) would lead me to believe we can not descend below MDH but I am open to other interpretations.
IEM 1.430 which refers to circling approaches also states repeatedly that you must not fly below MDA/H but is too long to paste here.
MM