How can you seriously say that you're flying VFR if there's no discernible horizon? The whole concept of letting non-instrument trained pilots launch off into the darkness with no reference to how much ambient light there is (ie moon phase, cloud cover, time of night) is an absolute joke, as Roy and HG would say.
Night flying in most conditions, if you have good instrument skills and a good understanding of how you're going to get down again once you get up there, is fine, but the whole concept is badly flawed when you consider the minimal training that is required to give someone a night VFR rating.