With two way switching there are two different combinations of switch poisitions that results in the light being off (and two different combinations of switch positions tha result in the lights being on).with lights off and we are not worried about with them on the brown wire between the switches is the only line wire. As long as we use the grey wire for this link then in off there will always be an earth wire between line and dead wires.
Look at what happens in your diagram when both switches are in the down position and you should see the problem.