Yes, that's the basis of your most recent attempt to defend the 'electrician'. Prior to that you were defending him on the basis that he probably "did what he was asked to do" (by a lay member of the public, who says he was not aware of the regs), and hence had a contracted agreement to install an inaccessible non-MF JB!
... and, as for "the argument that a removable panel is within the regs", as I said, there's surely no way that what the OP tells us the 'electrician' actually "knew (that the JB would end up above plastered-over plasterboard on the ceiling) constitutes a 'removable panel", is there?. Yes, as you suggested, the OP theoretically could have created a 'removable panel', but that was clearly not his intent, since we are told that the 'electrician' knew that that was not going to happen.
Assuming that this 'electrician' was aware of the regs regarding non-accessible JBs (maybe he wasn't?), it just doesn't make sense to me that he should do something which he had been told would end up non-compliant.