Show me a single scenario where, if you were never allowed to climb up from < circling MDA to then circle, where para D would ever be applied to anything.
Um, any time you fly a runway approach, which has a circling MDA, and you intend all the while to break off and circle?
Thus, you:
a) don't intend to effect a landing straight in on the runway (one example might be crosswind, thus "cannot")
b) you arrive at the circling MDA, do not have the visual reference, visibility, and enter the missed approach.
Ergo Para (d) in it's correct intent. No climbing back from lower etc...
Now, as with these things, there IS room for interpretation, and while I don't agree with yours, I can see where it comes from.
So perhaps it is better to simply say - and in my time, I've heard this from many older and (more importantly) wiser heads - "where there's any doubt, there's no doubt". Circling is dangerous enough as approaches go, and demands respect. Particularly in a heavy jet...
That's just my opinion.
CR.