I was never V-ray user and years back i was using only unbiased renderers where i learned to not use any "fakes". Projects i did in past never "forced" me to use any additional lights because only thing i was looking for was photorealism in nautral way. So no, i never use planes / lights in my interiors.
Most of them are HDRi + spot lights, like in real life. Im trying to keep my scenes simple.