In Murphy v. Allstate Ins. Co. (1978) 83 Cal. App. 3d 38, the insureds alleged that the insurer caused them to hire unlicensed and incompetent contractors to repair fire damage and that the repair work was inadequate, untimely, and caused additional damage to the property. The insureds alleged that the insurer fraudulently represented that the contractors were licensed and competent and intentionally delayed paying the claim. ( Id. at pp. 46-47.) Apart from delay caused by the repairs, the insureds also alleged that the insurer delayed paying the claim by requiring an appraisal as provided under the policy and by commencing an interpleader action against the insureds and contractors. ( Id. at pp. 47-48.) The insureds asserted causes of action against the insurer for fraud, conspiracy to defraud, bad faith, and intentional infliction of emotional distress and sought compensatory damages resulting from the inadequate repair work and delay, and punitive damages. ( Id. at pp. 43-44, 47-48.) The Murphy court held that the fraud and conspiracy causes of action were not " 'on the policy' " within the meaning of a limitation of action provision because "the conduct complained of occurred subsequent to the fire loss and the damages claimed were not recoverable under the policy." ( Murphy v. Allstate Ins. Co., supra, 83 Cal. App. 3d at p. 47.) The court held further that the bad faith causes of action were not " 'on the policy' " because "much of the conduct complained of ... occurred long after the fire loss and related to the repair and restoration of plaintiffs' home and personal property and the employment of persons and firms to do that work, the institution and prosecution of the interpleader action. Here again, the damages claimed were not caused by any risk insured against under the policy and were not recoverable under the policy." ( Id. at p. 49.) It held that the same was true of the cause of action for intentional infliction of emotional distress. ( Id. at p. 50.) The Murphy court rejected the insurer's argument that the bad faith causes of action were " 'on the policy' " because they were based on the implied covenant of good faith and fair dealing that arises out of the contractual relationship. ( Murphy v. Allstate Ins. Co., supra, 83 Cal. App. 3d at p. 48.) The court noted that all of the causes of action could be said to arise from the contractual relationship and stated, "there is a significant difference between 'arising out of the contractual relationship' and 'on the policy.' " ( Id. at p. 49.)