During the Fourth Great Shinobi war, Hizashi Hyuga is reanimated by Kabuto and is forced to fight against Hiashi. Why doesn't Hiashi use the curse mark and destroy Hizashi's brain cells?
The answer is simple, really. Because destroying his brain means nothing. Why? Because an edo tensei-ed person will rebuilt any broken body part after awhile, which is why the only way to fight them is to seal them.