She also referred to child witnesses who had given evidence that wrestling moves were performed on the three year-old.
Justice Potter said defence counsel had referred to the wrestling as games.
She said the Crown alleged that there were two main causes of Nia's death, the first being that she was allegedly kicked in the head by Wiremu Curtis and his brother Michael Curtis and the second that Nia's mother Lisa Kuka failed to get her medical treatment that could have saved her life.
Justice Potter told the jury of seven men and four women not to make inference from the fact that the accused did not give evidence.
She also told them that even if they believe the accused to have lied, it did not mean that they were guilty. She said people lie for all sorts of reasons.
Wiremu Curtis, who had been in a relationship with Kuka, 35, and his brother Michael Curtis, 22, have pleaded not guilty to murdering Nia.
Kuka, Michael Curtis's partner Oriwa Kemp, 18, and Nia's cousin Michael Pearson, 20, have pleaded not guilty to manslaughter.
All but Kuka are also accused of other less serious offences.
All five were in the courtroom this morning, flanked by three corrections offices.
During the month long trial, the Crown alleged Nia suffered months of abuse at the hands of the accused but it was the Curtis brothers who delivered the fatal attack, kicking her in the head on the evening of July 20 last year.
- Beck Vass with NZPA