Lawyers for the Waitangi Tribunal say it does not have to tell the Crown how much land to give back to claimants.
A group of claimants, including the Mangatu Incorporation, said the tribunal was wrong for not making binding recommendations for the return of thousand of hectares of Crown land.
Last year, the Tribunal said there were competing claims by the groups and urged them to mend their relationships and negotiate further with the Crown.
But a lawyer for one of the claimants, Kathy Ertel, said the body was required by law to make a binding referendum in favour of the group.
In court yesterday, a lawyer for the Crown said the Act says the Tribunal may include recommendations for part of the land to be returned, but it does not have to.
Justice Clifford was expected to reserve his decision.