You're right, I'm sure we could argue for ever and a day on that. My point being that if you have sight of the surface, you have a fixed feature to navigate to, or with - and therefore to retain that desired attitude without reference to the instruments.
The inference that a subsequent spiral dives ensues is that i am in solid IMC with no IMCr / IR? I do have an IMCr and wouldn't go off into solid IMC with it anyway (not for long journeys anyway) and certainly, I wouldn't advocate going pure VFR on top with masses of cloud around with sight of a solitary ground feature many, many miles away. It was just a technicality really.