Allegations that former Victoria police chief commissioner Christine Nixon misled the Bushfires Royal Commission have been described as a "gratuitous personal attack" by counsel.

After more than a year of hearing evidence, Thursday's final submissions from counsel assisting the commission focused on apportioning blame for failures of leadership during the Black Saturday bushfires.

Nearly 180 people died and more than 2,000 homes were destroyed when bushfires raged through large parts of Victoria in January and February last year.

Ms Nixon was singled out for criticism, along with Police and Emergency Services Minister Bob Cameron and retired chief officer of the Country Fire Authority, Russell Rees.

The inquiry's lead lawyer, Jack Rush QC, recommended the commission find Ms Nixon gave misleading evidence when she detailed her whereabouts on Black Saturday.

He says Ms Nixon's initial evidence failed to mention she had gone out for a meal on the night of February 7, leaving the impression she continuously monitored the unfolding disaster.

"It was a deliberate omission," he said.

But former Victorian attorney-general Jim Kennan SC, who appeared for Ms Nixon, says the allegations are "vague" and lack foundation.

"This is an attack on credit simply for its own sake," he said.

"The facts relating to Ms Nixon's conduct on the day in question are clear, they're not in dispute and we say for that reason this recommendation should not be entertained.

"It doesn't matter, we say, if she had the meal at home or had the meal out."

Mr Kennan says Ms Nixon's good character is beyond question and he has asked the commission to dismiss the recommendation.

Mr Rush began his recommendation by discussing the apparent failures of Mr Rees, who was accused of failing to adequately make sure the state was prepared for Black Saturday.

Mr Rees allegedly failed to get timely messages to communities under threat from the bushfires and failed to get involved in operational issues generally.

But Julian Burnside QC, acting for Mr Rees, says all the criticisms of his client were using the benefit of hindsight.

He says it was not Mr Rees and his senior management team that buckled under pressure, but rather the system itself.

"The fact that full information didn't get to Mr Rees on the 7th [of February] was itself something he did not know on the day," he said.

"He didn't know that he wasn't being told things that he needed to know."

Finger pointing

Mr Burnside told the commission finger pointing is not constructive and only serves to distract the royal commission from its true purpose.

"The report of this commission should try, wherever possible, to reach findings that are constructive, not destructive," he said.

Mr Rush also sought adverse findings against Mr Cameron.

"It is extraordinary the coordinator in chief, the Minister, would accept that those with the statutory responsibility for emergency management for leadership were not in a position to ensure a first-hand appreciation of the events as they unfolded," Mr Rush said.

"Surely emergency response demands this. A true leader would not contemplate anything else."

Mr Rush attacked Mr Cameron's and Ms Nixon's decisions not to declare a state of disaster.

"We find it incredulous as to their lack on consideration that was given to their declaration of a state of disaster," he said.

But the State Government's lawyer, Allan Myers QC, urged the commission not to accept the findings recommended against any individuals.

"These recommendations are apt to undermine morale in those organisations," he said.

"The criticisms give no adequate recognition to the extraordinary situation that existed on February 7, 2009.

"The individuals who were involved were subject to extraordinary pressures and it would be human to have overlooked things - to have made mistakes.

"We say please don't criticise them for it - that won't help."

Outside the commission, Premier John Brumby expressed confidence in his minister.