Presumably star positions in nighttime photographs could be used to determine location/time. Not very precisely but it could be enough to say the picture definitely wasn't taken at time/place that is claimed.
Edit: or even simpler, moon phases:
"Here is a photo of my client on the night of the murder so they have alibi"
"There was a new moon on the night in question but the photo shows a full moon"
Edit: or even simpler, moon phases:
"Here is a photo of my client on the night of the murder so they have alibi"
"There was a new moon on the night in question but the photo shows a full moon"