I'm not arguing that its safe, just saying how the rule can literally be applied. Reading that part of the ANO it seems to me that all you can do is interpret it, its hardly a comprehensive and detailed rule.
The ANO gives you a whopping 3 short sentences on the issue, I'm not saying PPL holders should break the law or fly beyond their licence limitations, only that specifics such as flying on top of cloud, or VMC at night or whatever, seem a bit vague or open to mis-interpretation within the ANO.
I totally agree about having escape routes but surely that is an airmanship consideration?
I'm not trying to argue but just trying to understand this issue myself as it seems to me to be a bit of a 'grey area'!
I have always found the ANO to be a bu$$er to understand, thats why idiots guides like the MATS Pt 1 were introduced but with this particular issue the ANO appears to be less than informative or definitive.
Lets talk about VFR at night shall we? ....a much more straight forward topic!!!!!!!!!!