At first glance Top one looks more proper/correct. The steel clip is a basically a anchored hardware. If you can turn it one way and insert it from backside ( like the bottom one ) that would probably work, although the depth of the anchor limits travel a little. In some examples there isn't access or space to insert it from backside ( blind hole or tight in a corner ).
On the other hand... There is a spring applying some pressure on them. Which way is stronger, less apt to pull out? The bottom one, inserted from the backside.
From the factory there very well could have been one this way and one that way. Like one pre installed in the fender and the other hanging on the headlight bucket. They hooked the one screw head and the spring to the bucket then poke the other anchor in, done. Betcha somebody here has OEM example of your year model ( what ever that is ).