> Even if it is a non-INVITE request?

RFC3261 section 12.2.2 applies to all requests within dialogs.  However it
obviously does not apply to CANCEL or ACK.  And it obviously does not apply
to retries of requests still remembered at UAS.

Another section vaguely discusses out of order cseq for known registrations.

In general for requests outside of a dialog (excluding known registrations),
the UAS is not required to notice out-of-order requests beyond observing
retries (when required or possible).



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