Does a part performance claim an insurable interest in a property where the tenant has made substantial improvements to the property?

On the other hand, in Roberts v. Colwell, supra, the plaintiff had a lease of a house. He claimed that the owner had entered into an agreement to sell it to him. As acts of part performance he pointed to entry into possession of the land surrounding the house, and improvements he had made and money he had spent on the premises. Baxter J. held that these acts were not unequivocally referable to the alleged agreement for sale, that there was no visible difference between the occupancy under the lease and that under the alleged agreement, and that the improvements were such as a tenant would make. The improvements described in the judgment were of a very slight nature. By contrast, the owner made substantial improvements upon the property, paid the taxes and kept up the insurance. (In respect of the latter, Baxter J. observed, at p. 461: "Evidently the (plaintiff) did not consider that his alleged purchase gave him an insurable interest in the property.")