The way I read 61.57(d) (the requirement for an IPC), it's just an extra
requirement that kicks in under certain circumstances. It's not a subpart
of 61.57(c) (6 approaches etc in 6 months), and (c) does not have any
exceptions related to (d).

So if an IPC is essentially a checkride, it could be done by a proficient
pilot with (say) 3 approaches. Would that pilot be legal for IFR if he
had gone into the IPC needing it (no approaches within 6 months)?

--
Ben Jackson AD7GD

http://www.ben.com/