In QBE Insurance (International) Ltd v Allianz Australia Insurance Ltd [2018] NZCA 239 the Court of Appeal upheld the High Court decision that Allianz was not liable for earthquake damage because its insurance policy did not commence until 4pm on 4 September 2010 in relation to the earthquake that occurred at 4.35am.  The QBE policy ended at 4pm on 4 September 2010 so it was solely liable.  The agreement between the insured’s broker and Allianz on placement was that the Allianz policy would incept on the expiry of the QBE policy.  Any later documents could not affect that agreement.