Perhaps. People often get confused between the 'Building Regulations' and the 'Approved Documents'. While, if followed, the Approved Documents provide a route to compliance, non-compliance does not automatically follow from a failure to adhere to the advice provided within the Approved Documents.
In this instance, the regulation requires that 'there shall be adequate means of ventilation provided for people in the building'.
Here, we are concerned with 'purge ventilation', i.e. the 'manually controlled ventilation of rooms... to rapidly dilute pollutants and/or water vapour'. The approved document acknowledges that adequate Purge Ventilation may be achieved by 'natural means (e.g. an openable window)' and goes on talk about this in more detail in the appendices.
Well that's a new one on me......Is that something you have successfully obtained Building Regs approval for or is it just a hypothetical exercise? Not having mechanical ventilation in a bathroom seems like a sure fire way to ensure you get condensation problems not to mention the fall out from certain other bathroom activities, especially after a curry.