MM_Flynn
Your argument is sound and your observation about accidents during an approach is very relevant.
G-BIWP
The aircraft had climbed through the cloud and was in VMC above a cloud layer.
G-BXLJ
The pilot who hired the aircraft had not flown since 28 November 1998; consequently the AFI accompanied him in order to satisfy the operator's 4 week currency requirement. The AFI not surprisingly was recorded as the Commander and he also held a CPL. It is not known whether the aircraft was above the tops or not.
G-LIMA
I understand this is the accident referred to by the CAA.
Italics = quote from the AAIB report.
I am not sure your assessment of these accidents is quite as sound for the above reasons. Unless there are any more of which you are aware perhaps the CAA are correct.