IO540,
You are correct it should have said "with passengers". However, the idea is that the CPL and the IR confer night flight privileges and thus it is only natural that night training and the medical requirements for night flight are met in those cases.
Yes, the CAA could issue someone who is deaf and colour blind with a PPL-IR limited to flight with a hearing current IR rated pilot by day in UK airspace only. How many would want that?
If exemptions are issued to cover every this and that then we would need an exemption authority reporting to the CAA. Unfortunately the line has to be drawn somewhere.
Having had a think about the IMC rating, I actually find it unusual that the IMC rating can be issued without a requirement for the applicant to hold a night qualification.
What are UK ATC supposed to do with a holding stack at sunset? Start asking all the holding aircraft if they can continue to hold after sunset+30?.........and the one at the top says - I've only got an IMC rating, I need to land!
Then all the IR holders say "I've got an IMC rating too let me lad first"
Regards,
DFC