This is why the FAA does not allow solo night flight by VFR students. Too dangerous for the 3 hours of instrument time they have. It really is instrument flying, despite the categorization as VFR. It is also risky for those who have an engine failure in a single engine airplane, no matter what the experience level. I teach my students to always plan night flights within gliding distance of an airport along the way, and be forever ready to execute a diversion if the engine quits.