[stmt.return] p3

The destructor for the result object is potentially invoked ([class.dtor], [except.ctor]).

[class.dtor] p15

A program is ill-formed if a destructor that is potentially invoked is deleted or not accessible from the context of the invocation.

For [stmt.return] p3, What is the context of the invocation for it?

Infer from the example under [stmt.return] p3, Should it be that?

The destructor for the result object is potentially invoked ([class.dtor], [except.ctor]). In this case, the context of the invocation is the context of the return statement.