Stephen Bailey has been charged with the murder of his mother, Penny Bailey, whose body was found in bushland on Thursday night.
Ms Bailey was last seen at her Mont Albert home on Sunday and reported missing by her family two days later.
Investigators found her body near the Mullum Mullum Creek in Donvale two days later.
Bailey, of Mont Albert, was arrested on Thursday before his mother’s body was located.
Bailey was not required to appear in court on Friday afternoon at the request of his lawyer, Christopher Dane QC.
Mr Dane told the court his client needed to be returned to a secure psychiatric hospital as a matter of urgency.
He told Magistrate Jan McLean he was extremely concerned for Bailey, who was in an “extremely florid” state and had been sedated to the point that he could not be raised in the morning.
Ms Bailey is the daughter of Laurie Kerr, who played 149 games for Carlton Football Club in the 1950s and was named in the club’s team of the century.
He later founded public relations company International Public Relations.
Her mother Vivienne Kerr is currently the number one female ticket holder at the Blues, while her sister Judy Mullen is the president of the Women of Carlton coterie group.
Stephen Bailey played football for Box Hill in the VFL, and West Adelaide and Norwood in the SANFL.
In a statement, Ms Bailey’s family said she would be remembered for her “warm heart”.
“The Kerr family would like to publicly express its gratitude for the outpouring of support it has received since Penny’s disappearance,” it said.
“Penny was a beautiful woman and mother of three children. She will be remembered for her caring nature, warm heart and love of family.
“The Kerr family is large. Vivienne and Laurie Kerr had nine children – there are 34 grandchildren and 24 great grandchildren.
“The entire family is focused on providing Penny’s daughters, Belinda and Shannon with comfort at this time.
“We would also like to thank the Victoria Police for their professionalism and the caring and sensitive manner in which they conducted their investigations.”