MasterCaution,
My interpretation (probably wrong) is that the conditions for the JAR FCL are as laid out in the ANO, i.e. no PPL IFR in A,B or C without an IR and no IFR in D or E without an IR or an IMC. The reference to IMC in itself seems to corroborate my view (well with my twisted logic it does!). By that I mean not just a side effect of the night qual but also the IMC.