I guess it depends on what it says in your ops manual. But this also exists in EASA AMC & GM for Part-FCL:
"GM1 FCL.060(b)(1) Recent experience
AEROPLANES, HELICOPTERS, POWERED-LIFT, AIRSHIPS AND SAILPLANES
If a pilot or a PIC is operating under the supervision of an instructor to comply with the required three take-offs, approaches and landings, no passengers may be on board. "
I'm still not sure if the AMC & GM is law!
