The prosecution has argued the footage, which shows black and brown cardboard figures inside the building and some hanging off as if falling from it, is also racist in its content.
The court heard that Bussetti had frequently used racist terms including "Paki" and the N-word in other WhatsApp chats.
Among details given to the court were a message from Bussetti stating "N***** priest as well" in a conversation about the wedding of the Duke and Duchess of Sussex last year at which US preacher Bishop Michael Curry gave a sermon.
Mr Summers argued that content in the effigy footage was "nowhere near racist hate speech such as to take it outside Article 10".
He cited comments made by Boris Johnson before he became prime minister including people in the Congo being "tribal warriors" with "watermelon smiles", and a 2018 Daily Telegraph column in which the Tory MP described veiled Muslim women as "looking like letter boxes".
Mr Summers told the court: "We say that none of these things cross the high threshold of hate speech but all of them have emanated from the mouth of the man who is now our prime minister. And he has not been prosecuted for any of them."
Of the effigy, Mr Summers went on: "This was, whatever one thinks of it, an artistic effort. It was a model. It was satirical."
