I think the law is you can't have 2 fixed backs, because you can't recline the seat forward for the people in the rear in case of an accident. But having one fixed and a recliner passenger would still allow this. Best bet is to buy the best seat you can find, you've got to sit in it every day and use it everyday so why cheap out on it?
I love my seats in the GT-R but am thinking of upgrading to 34R seats. Also my 32R seats are mint. No tears or holes, barely look used.