Stevelup
As you say, the wording of both quotes from the ANO are almost identical, very interesting. If I could get my laptop to open the CAP393 pdf I'd have a good look, but from the quotes it looks like you're maybe right.
Ryan5252
That is indeed a possible way round the restriction, however not everyone is or indeed should allege, they are doing a modular CPL. Should something happen to draw attention during the "solo" flights, you may have to justify your assertation that you were hours building for a CPL. Also it's not necessarily the CAA you'll have to convince, but an insurance company, from my experience they will seize upon any opportunity to not pay a claim.