My thanks to swh for the "Non-operational chart". If this chart is an accurate representation of the real one, I can make a few comments. My apologies in advance for the lengthy nature of this post.
Firstly, maybe I'm missing something, but I don't see an IAF marked anywhere on the chart. This is probably a minor point, but makes me wonder exactly where the approach starts. After all, it's only the precision segment that starts at GP intercept and there has to be a way to get there. In absence of any other information, I believe that the holding pattern at BN is a racetrack procedure and, therefore, BN is the IAF.
I am not accustomed to seeing an initial segment indicated by a dotted line such as those used to indicate feeder routes and the racetrack at BN. Thus, I'm also trying to come to grips with the way things are depicted on this chart, so that I don't confuse the issue by thinking in terms of our own depictions.
The first extremely relevant point is that the GP angle appears to be 3.6 degrees, which I note is 0.1 degrees above the maximum angle for which Pans Ops provides OAS data. Such an angle will not be used unless there's a significant obstacle problem, so my first comment is that this is not a procedure where one should take too many liberties.
Anyway, it occurs to me that, if you happen to be tracking 220 degrees toward BN, you certainly are quite close to the LLZ track of 217. Depending on what your AIP says about pilot tracking tolerances, you may actually be allowed to slide across from the 220 track to the 217 track.
That would certainly be the case where I am because there will be an overlap between the tracking tolerances for the NDB and those for the LLZ. Given that there seems to be no other information on that chart, I would venture to suggest that the "slide-over" is the way that one is intended to intercept the LLZ.
This would also mean that it would be possible to descend to 3000 feet during the "slide-over" manoeuvre from one track to the other. The problem is that you must know the outer limit of the protection on the 220 track to BN. This is because the 3000 feet limitation seems to be available only within the racetrack. There is no indication on the chart of the DME distance at which one could descend from 3200 to 3000.
The result of this lengthy ramble is that, without radar vectors, it would seem that one must maintain the MSA until reaching GP intercept. The only other issue would seem to be whether or not your AIP allows routine use of the MSA, as we do here, or whether it is only available in an emergency.
To me, therefore, it seems that you are required to go around the racetrack to take advantage of the descent to 3000 feet. Then, having turned inbound 220 to BN and within tracking tolerances of the LLZ, diverge right just enough to make the intercept of the LLZ - hopefully prior to GP intercept.
Given the circumstances, therefore, I think that the captain was probably correct on this occasion.