I know of a J-box behind an upper kitchen cabinet. :roll: It only requires a screwdriver to access.
I don't agree. IMO, you can remove all of the cabinets in a kitchen and not disturb the "building finish" at all, which is the drywall.IMO that would be concealed by the "building finish".
What about the receptacle for the fridge?
Would you still consider a junction box to be accessible if behind a fridge? The fridge is fastened in place with 8 screws, 4 on each side.