As the answer from mike and the comment from MarkusOdenthal did not work for me when I used the jupyter docker stacks I looked for a different solution and it seams using overrides.json is the current recommended approach:
https://jupyterlab.readthedocs.io/en/stable/user/directories.html#overridesjson
In short: check the application directory with jupyter lab path and place a file named overrides.json containing
{ "@jupyterlab/apputils-extension:themes": { "theme": "JupyterLab Dark" } }
into <application directory>/settings/ (e.g. /opt/conda/share/jupyter/lab/settings/ for the official jupyter docker containers)
So if you want to have the base image from jupyter with dark theme, the Dockerfile would be
FROM jupyter/base-notebook COPY overrides.json /opt/conda/share/jupyter/lab/settings/