2D,
I accept your interpretation than 49 does not apply to airports with DIY approaches.

I still think the minima for an IMCR holder when shooting a published approach (as found in the AIP) are not recommended but mandatory.
I still don't feel beat up
So far though, still nothing to convince me that you have found a law prohibiting descent below MSA other than on a published approach, but I am open to offers.
Let me think about that one