When playing in survival without cheats, you can set your playerssleepingpercentage gamerule in pure survival, which you can possibly set yourself to prevent the night, even though it is not supposed to happen without cheats.

Step to Reproduce
1. Create a new world without cheats in survival mode
2. Set and try the gamerule command to prevent skipping the night:
/gamerule playerssleepingpercentage 101

Expected Result
You're unable use the playerssleepingpercentage gamerule without cheats.

Observed Result
You can use the playerssleepingpercentage gamerule without cheats.