If there is no shower in the bathroom, it woold be a stretch to say there is a circuit. If this was a pro installation, there would be an EIC. Surely this is a new circuit.
Good to see you, and I hope that all is well with you and yours.
I have to say that your view doesn't really corresponds with what I would regard as common sense, even though I cannot deny that, if taken literally, the BS7671 definition implies that if there is wiring (originating at a CU/DB, and protected by an OPD) which had no connected 'electrical;' equipment,then it is not "a circuit".
Addressing first the details you mention, it
was a "pro installation" and there
is an EIC - and, in any event, there should be an EIC even if it had not been a 'pro install'. If you're suggesting that what they installed was not 'a circuit', what would you call it?
Would you have a different view if this <whatever you call it> (at the time connected to nothing) had been labelled "Water Heater" where it originates at the CU, rather than "Shower" (which it currently says)?
When the property was re-wired, about 20 years ago, it was totally empty, with no hard-wired electrical loads at all, other than lighting. As I've explained, they installed a shower circuit "in case an electric shower was installed in the future" (even though there was no shower at the time, and still isn't'. They similarly installed a cooker circuit, an immersion circuit and an 'outside lights' circuit "in case an electric cooker, immersion heater or outside lighting was installed in the future" (even though none of those things were installed at the time,and still aren't).
Are you really suggesting that (despite BS7671 definition) it is sensible or useful to say that none of those are 'circuits' - and therefore that, by implication, if anyone ever connects anything to <whatever you wish to call them>, they would thereby be 'installing a new circuit"??
I have to say that suggestions such as you have made (which some might call 'pedantic') are probably one of the things which "give a bad name" to rules, regs and laws and thereby very probably reduce the extent to which some people take them seriously.
Kind Regards, John