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For something which has not happened yet, I'd certainly recommend putting the agreement in writing. No fancy contract with legalese needed, just something in plain language, agreed to in writing by both parties.
For something which has already happened, sure the photographer can start a dispute, but the only guarantee is that it will be unpleasant for everyone involved. If she has nothing in writing saying she can use the images, she most likely can't keep using them. On the other hand, he probably can't either.
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