A possible exception to this is when your bees have other things to worry about!
We moved a couple of colonies and arrived after dark at the new site. Although a lot of bees spilled out when they were opened up (crawling all over the front of the hive, some flying), they were pretty hot and bothered and didn't worry about us at all, just cooling the colony and getting some fresher air in.
Unless I'm really short on time, I don't think I'll be doing inspections by torchlight though!