Um, any time you fly a runway approach, which has a circling MDA, and you intend all the while to break off and circle?
In the scenario you described, the deletion of Para .d from the AIP would have
absolutely no effect on what you're talking about. You could do all that you described, without para d having ever been written.
Hence I disagree with you.
For the record im not saying its a good idea, in most cases I wouldn't be doing this in my aircraft (cat C) because its often asking for trouble.
But by strict letter of the law (and I've spoken to Casa on more than 1 occasion about this exact issue), its legal to do what I've described.