Andy, we're going off topic, so I won't go on and on with this, but there are ways. We do get referrals and students sometimes buy their books at home for self-study before they arrive; though those cases may not add up to big numbers, they do create loopholes that might be exploited. As I said, I don't know how widespread this practice is, but I can say, without one shred of hesitation, that at least one shop on Tao does the used-manual 'rule bending' scam. If one op does it, I would suspect that some others do as well. I haven't heard any rumblings of a PADI crackdown here in Thailand, though I suppose AP HQ could have a quiet 'word' with an offender.
Moving back towards the topic, JDL do say they provide a book with their cheap course, so they must have some other way to cut costs in order to make a reasonable profit.