The door may still be open for insurance companies to rely on the merger doctrine to limit their liability for Christchurch earthquake claims. This is one of the implications of a recent Court of Appeal judgment1 relating to an insurance dispute. The merger doctrine…originates from UK marine law and is potentially relevant to Christchurch because it applies to circumstances where damage is sustained across successive events. It provides that: “Where under the same policy, a partial loss, which has not been repaired or otherwise made good, is followed by a total loss, the assured can only recover in respect of the total loss”