It can take a phone a while for it to get a fix without data access, sometimes a few minutes or more if the ephemeris data isn't up to date.
If your phone has no location at all when the pictures are taken (GPS is turned off, or hasn't got a fix yet) I doubt it will go back to the pictures after the fact and update the location. So either the pictures will have the last known location or no location at all (I'd say no location, putting in an old location into the photos could be more annoying than no location).
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Uncertainty is an uncomfortable position.
But certainty is an absurd one.
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