Disconnect inside a cabinet

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What is the reason for installing it this way?

I've installed disconnects reachable by the public, and the solution was to drill a hole or two through the handle mechanism and lock it on to prevent tampering.
 
Is the disconnect required to be accessible or readily accessible?

Accessible (as applied to equipment). Admitting close approach; not guarded by locked doors, elevation, or other effective means. (CMP-1)
Accessible, Readily (Readily Accessible). Capable of being reached quickly for operation, renewal, or inspections without requiring those to whom ready access is requisite to take actions such as to use tools (other than keys), to climb over or under, to remove obstacles, or to resort to portable ladders,
and so forth. (CMP-1)
Informational Note: Use of keys is a common practice under controlled or supervised conditions and a common alternative
to the ready access requirements under such supervised conditions as provided elsewhere in the NEC
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