I have never heard of anyone using class javadoc comments before the class declaration. I'm no sure how the JavaDoc tool would handle that.
Sun officially recommends putting it right before the class.
A doc comment is written in HTML and
must precede a class, field,
constructor or method declaration.
My interpretation of the above is that a comment describing a class that does not immediately precede the class declaration is incorrect.
In most companies that I have worked in, the part before "package" will only contain copyright notices and disclaimers, for legal rather than technical reasons. Something about putting all disclaimers before someone had a chance to view any content. This is common practice. Most developers skim that part of the code, and many IDEs will auto-insert this legalese.
The only organizations in which I have seen module level documentation before java "packages" are ones that are traditionally C++ organizations, where putting description at the beginning of an H file is more common.
All that being said, coding practices are just a recommendation. The unfortunate reality of mandated practices that do not make sense is that someone in power believes they know better. They might not appreciate mere mortals questioning them.
If you want to try and convince them otherwise, run the JavaDoc tool and examine the generated files. If there are no class-level comments, you have a good argument that you might win.