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Im pretty sure you need to drop the subframe to get it out mate. When mine was done, we lifted it out of the top with only the gearbox mount bolted up and even then it was tight!
I've done it quite a few times in the car, it's a bit awkward getting the sump past the subframe, getting height is the key. Wouldn't go to the effort just to clean it out though, unless there's a problem you know about.