... I had infringed JAR-FCL regulations
There are no such things! JARs are Requirements, not Regulations - a fact not appreciated by many throughout the entire JAA existance (it no longer exists btw) - and it is up to the NAAs (that's the CAA in the UK) to interpret them and make them Regulations. JAR FCL details requirents related to gaining a licence or rating and has nothing to do with how you operate an aircraft. The only document (other than a local club/school rule) that will say which seat the PIC must be in is the POH or FM (or RFM.)