Not saying airspace and controllers didn't contribute to the tragic outcome, but put yourselves in the pilot's position - any VFR pilot knows he has to maintain, if not AIP stated vis and distance from cloud conditions to the metre or foot, at least a decent bit of clear airspace out front to continue into and, let's hope, room to turn around if it clags in too much. The investigators found that the aircraft was descending clean in a straight line with cruise power set, not weaving around as you would if you were trying to scud run under low stratus through some hills. I cannot visualise a situation where as a VFR pilot I'd descend into, if not cloud, then at least conditions of such reduced visibility that I couldn't see far enough in front of me to know whether or not there was anything to hit, can you? - and he must have known there was cumulo granite there, surely.