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this is the behavior defined by the specification. The simplification
algorithm is described in the Relax NG specification; the constraints
are applied after the simplification step. And after the simplification
step, there are no references in the list expression in your case.
The quoted link is right, as are the words at the beginning of the
same page saying that all constraints are applied to the simplified
The constraint basically means that elements cannot reside inside
lists, which is how it should be.
> but is that just a practice used by some
> validators, or is this the behaviour defined by the specification?
All conformant validators will treat your grammar as a correct one.