Perhaps the regs need to be re-written
to state that to depart under the NVFR the take off or landing shall be conducted in the Daylight. This will therefore establish the spirit of what NVFR is intended for (to depart before first light or arrive just after last light).
I've blasted off under the NVFR in a single engine aircraft quite a few times without a CIR. To say it is foolhardy is an understatement.
I scared the absolute **** out of myself one time. Months later a C210 came to grief in the same place in a similar situation killing the Pilot.
The ATPL night hours are not worth your life.
I was lucky.