A pathologist told the inquest into the death of Poppi Worthington there is not enough evidence to conclude she was assaulted before her death.
But Dr Liina Palm also said she could not rule out that the 13-month-old was abused shortly before she died, Kendal Coroner's Court heard.
Poppi was heard to scream before her father Paul Worthington put her in his bed with him and went downstairs to get a nappy around 5.30am on December 12 2012 at the family home in Barrow, Cumbria.
He went back upstairs, thought she had settled but then reached across and discovered she was limp, he told police.
Undated family handout file photo of 13-month-old Poppi Worthington, who died in December 2012
Dr Liina Palm also said she could not rule out that the 13-month-old was abused shortly before she died by her father, Paul (pictured in a court sketch) Kendal Coroner's Court heard
The 49-year-old ran downstairs with her, an ambulance arrived at 6.05am and as there were no signs of life, paramedics carried out a 'scoop and run' but she was declared dead at Furness General Hospital a little over an hour later.
Home Office pathologist Dr Alison Armour, who carried out the post-mortem examination, has told the inquest she is 'sure' the girl was abused before her death, citing the blood and evidence of tears and bruising.
Later, a judge in family court proceedings ruled on a balance of probabilities her father had sexually assaulted her before she died.
On Thursday, Alison Hewitt, counsel to the inquest, asked Dr Palm, who reviewed the hotly disputed medical evidence, of her view that Poppi had been penetrated as Dr Armour suggested.
She replied: 'Based on the tissues only, I think there's not enough evidence to support this view.
'I can't exclude penetration. I'm not sure. There's not enough medical evidence to support that penetration, as such, has actually occurred.'
A police investigation was so botched and vital evidence lost, no charges have ever been brought for anyone over Poppi's sudden death and much of the inquest attempting to find out her cause of death has relied on medical evidence.
But there have been significant points of dispute between the experts, with Dr Armour's post-mortem findings questioned.
Poppi's cot. She was heard to scream before her father Paul Worthington put her in his bed with him
Most contentious has been the significance of tears in the child's bottom.
Gillian Irving QC, representing the mother, who cannot be named for legal reasons, asked Dr Palm: 'It has always been your nemesis, this question, hasn't' it?'
'It has,' Dr Palm replied, who agreed she did not have a ready explanation for it, though again said it may not be only as a consequence of trauma from penetration.
The Crown Prosecution Service has twice ruled there is insufficient evidence to prosecute anyone over her death.
Mr Worthington, who is now in hiding, has never been charged with any offence and strongly denies any wrongdoing.
The hearing continues.