If you can’t see sh***, you’re not flying NVFR
You certainly can be.
2.1.5 Flight under VFR—by day or night—must be conducted in visual meteorological conditions (VMC) and in compliance with minimum inflight visibility standards and prescribed vertical and horizontal distances from cloud
Decrees the weather standard, atmospheric transparency, not a level of illumination, see 2.1.7.
2.1.6 NVFR operations are not the same as flying at night under IFR, even though proficiency in instrument flying and use of radio navigation systems is required. It is important to remember that NVFR flight is based on visual procedures in VMC
Proficiency in instrument flying is required, guess why, because you may not have the conditions to fulfill the recommendations of 2.1.7.
2.1.7 CASA strongly recommends that NVFR operations take place only in conditions that allow the pilot to discern a natural visual horizon or where the external environment has sufficient cues for the pilot to continually determine the pitch and roll attitude of the aircraft
Recommendation, not a requirement.
As with any rating, to utilise the skill to the full you require good training, experience and recency. All 260 night hrs of mine were NVMC, I can only recall having a natural horizon on one occasion, the view out any window on most occasions was (over water where most of my work was done),
