The lawyer for a Christchurch couple says the repair work Tower Insurance proposes to do on their quake damaged home would not bring the property up to near new condition, as is contractually required.
Matt and Valerie O'Loughlin's lawyer, Grant Shand, is summing up their argument in the case against their insurers in the High Court in Christchurch.
The couple want their red zone property to be rebuilt but the insurer has offered to pay only for repair.
In his closing submission, Mr Shand said the work proposed by Tower would not bring the property up to a new condition - which, he says, the policy stipulates.
He says the insurer's repair proposal would not remedy the water damage, or level some walls.
Mr Shand said according to the building code, the repairs must last for 50 years, something the insurer could not confirm is possible.
He also told the court the property could not be returned to a new condition because it is likely services such as power and water will be cut off to the red zone.
A lawyer for Tower Insurance, Alan Galbraith QC, said the insurer is prepared to meet the O'Loughlin's wish of a cash settlement, and the only matter in contention is the amount.
Justice Asher reserved his decision.