The same circuit could have been arrived at by designing from Boucherot's minimising reactive power point of view. From this design approach there is no difference in the order of the capacitor and the resistor and Boucherot cell might be considered a more accurate description.
The same circuit could have been achieved by designing from Boucherot's viewpoint of reducing reactive power consumption. This design method does not distinguish between the placement of the capacitor and resistor, and Boucherot cell might be viewed as a more accurate representation.