Thanks 2donkeys,
I am guessing you are basing your argument on the following..
Minimum height
29. Without prejudice to the provisions of rule 5, in order to comply with the Instrument Flight Rules an aircraft shall not fly at a height of less than 1000 feet above the highest obstacle within a distance of 5 nautical miles of the aircraft unless:
(a) it is necessary for the aircraft to do so in order to take off or land;
If you are using this to say you can do what you want if you are taking off or landing, then can you descend to 100ft AGL in cloud? Is there actually a MDH if there is no published approach?