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First time I've noticed this, does this mean when installing a socket outlet for a permanent appliance (like an oven) that it's not compliant to have it behind the appliance? And that it would need to be in a location such as a nearby cupboard so it doesn't have a permanent fixture or fitting restricting it?

But an oven isn't a permanent fixture or fitting, it's an appliance, and those with wheels are a portable appliance.

An in-wall or under-bench oven is a fixed appliance.
A free-standing range isn't (though I wouldn't call it "portable".

But this paragraph of the rule isn't about whether an appliance has to move before you can get to the plug & socket;
It's about being able to remove the plug from the socket at all.
ie not having anything so jammed up against the plug that it can't be removed, or can be removed only with difficulty.

For a range, or a fridge, as long as you can move the appliance to get to the socket, this para doesn't prevent locating the socket behind the appliance. Unless the appliance is a gas appliance, and the socket is the chosen means of isolation for it; as per the Note.

For an oven, even though almost all are screwed in position (i.a.w MIs); when it comes time to access the plug you can still unscrew the fixings and remove the oven. That would be a breach of this para; as a screwed-in appliance has to be a "permanent fixture".
Same for microwaves in camper-vans, where they are securely held in their alcove by a screwed-in batten or similar.
I believe still better to use a socket than a PCU for this application; as long as the flex isn't so short that you can't put the oven down on the floor before reaching in to unplug. So better to locate the socket in the next cabinet, as is common for dishwashers. That way is always compliant.

Noted, and that was my thinking but I'd never noticed this part of the clause before

Interestingly I don't think it's something many people would be aware of

I suspect that's because it's over the page from the rest of the clause

Further question, can a socket outlet be inaccessible?

Since "inaccessible' means it can't be accessed short of demolition;
it's technically possible; but would be pointless.

What about ESR 20 (2) i? Does that come into play?

which item did you have in mind?
(d) wouldn't be a problem, as a plug 7 socket is secure & reliable.
(i) only becomes a problem if there's a need to do any of the olosted actions. Bit since it doesn't eliminate a fixed connection being hidden within the structure; It can't really be used as reason not to hide a plug-&-socket within the structure

(i) was what I was referring to, I've just seen many people use this argument against it so was just curious of your thoughts

I presume they are making an assumption that because it's a socket outlet; someone must need to get to it for one or more of the purposes listed.
If that assumption is correct, then yes the ESR would make it electrically unsafe to have the socket not accessible.
But need to consider whether such an assumption is actually correct; case by case.

Not that I'm suggesting it's a good idea to have inaccessible sockets (presumably with plug plugged-in); just that it isn't automatically forbidden.

If it's just behind an appliance cover, like a rangehood cowl, then it's not really inaccessible, you just have to remove a cover to get to it. So it is possible to "access" it, as per ESR20(2)(i).

My current opinion =

4.4.2.2.d would suggest it's OK to have a power point behind a fixed appliance or in a location that's not readily accessible as long as its soley for that appliance

4.4.2.1 also uses the words "any plug intended to be used"
Which suggests to me if the socket is for general use it must be readily accessible for that purpose, if its just for an appliance and the only plug intended to be used in it is the plug of that appliance then it is not restricted by the appliance as its only going to be accessed with appliance is also removed so in this situation its only required to be accessible.

?

I agree in general.
But note that gas appliances are a bit different. 4.18.1.1 ays that of the socket is used as the means of (local) isolation; it must be accessible with appliance in position