I remember being told by a very Senior Examiner (remember them) that soon after NVFR was introduced he had to do a flight test for the issue of the NVFR departing from an outback town.
On the flight test the take-off, towards a well lit town was normal. As soon as they entered what would be downwind for departure, he had to recover the aircraft three times before calling the test off and landing.
As soon as the applicant lost sight of the town lights, he had no outside visual reference in what was a moonless night and could not keep the aircraft straight in a climb.
To make matters worst, the occasional lights from homesteads merged with the stars.
That obviously wasn't NVFR then as there wasn't a discernable horizon.