+1 on this entire rely.

Riding at night, you often hit potholes without warning and a few extra mm of air give you protection against damage and punctures. I find that 32mm are overkill for fast road commuting but fine for rough tracks.
The main decision is what kind of brakes are going to give you the required tyre/fender clearance. You can always fit narrower tyres but brakes limit the wider selection. I find that long drop calliper brakes are a good solution with enough room for 28mm+ fenders (mine can fit 32). The only other contender, for wetter conditions, would be disk brakes.
Note that 28mm seem to be the most variable tyre in terms of actual, measured width.