When Adrian Ernest Bayley was jailed for the rape and murder of Jill Meagher, he was given a non-parole period giving him a small window of time when he might live outside jail.
From Thursday, that window will get even smaller.
Bayley, 43, is due to be sentenced for attacking three more woman after he was found guilty of crimes including rape, assault, threat to kill, indecent assault and false imprisonment in separate trials in 2014 and 2015.
He raped an 18-year-old woman in St Kilda in 2000 and a 25-year-old woman and a Dutch backpacker in 2012, months before he strangled Ms Meagher.
It brings his total number of rape victims to 10.
His attacks involved luring women into his car then driving to a secluded laneway where he would park with the passenger door against a fence and brutally rape his victims.
One devastated woman was left with road tar embedded in her leg, something she has to look at to this day, the Victorian County Court heard on Wednesday.
“I’ve seen real fear, as in, `That’s it, I’m going to die’,” she said in a victim impact statement read to the court.
Another victim said she started cutting herself as Bayley’s trial drew near and attempted suicide when it was delayed.
She said she turned to drinking to forget the crime, and had become an angry and scared person.
“I now try to look like a boy so that men would leave me alone,” she said in a victim impact statement read to the court.
The third victim said it was only after the trial she realised the attack wasn’t her fault.
Prosecutor Peter Rose said the fact Bayley was on parole and appeal bail during the 2012 attacks was an aggravating feature of his crimes.
Judge Sue Pullen said she will increase Bayley’s minimum jail term when she sentences him on Thursday.
Under the current sentence, which has a non-parole period of 35 years, Bayley will be eligible for release at age 76.
Defence barrister Saul Holt did not argue with the proposition that the non-parole period be increased.
“It’s only a matter of how far,” Mr Holt said.
Bayley was dressed in a blue shirt and navy tie with his hair pulled back into a ponytail for the hearing.
When asked for his address he gave a smile, and a little laugh and said, “ah, Melbourne Assessment Prison”.
The court heard he is only allowed out of his cell for between one and three hours a day.
Bayley will be sentenced at noon on Thursday.