Underworld kingpin George Marrogi's conditions in custody have been cruel, inhumane and degrading, his lawyers have argued.
Marrogi, who is serving a 38-year prison sentence for murder and drug trafficking, is suing Victoria's Department of Justice in the Supreme Court, arguing his human rights have been breached.
He had a legal win in January, when Justice Claire Harris found some of the yards at the two prisons he's been housed in - the Melbourne Remand Centre and Barwon Prison - did not have open air.
The judge also ruled there were dozens of occasions between May 2023 and June 2025 where Marrogi's right to dress in private after a strip search was breached.
At a further hearing on Friday, Marrogi's barrister Sarala Fitzgerald SC argued her client was experiencing cruel, inhumane and degrading conditions in custody.
She pointed to the Mandela Rules - a set of standards for the treatment of prisoners set out by the United Nations.
The rules state solitary confinement is when a prisoner is without meaningful human contact for 22 hours or more a day and prolonged solitary confinement is when those conditions extend past 15 consecutive days.
Ms Fitzgerald told the court between November 2023 and March 2025, Marrogi generally spent 23 hours a day in his cell and he was not allowed to interact with other prisoners.
When he was able to leave his cell, Ms Fitzgerald argued Marrogi was still confined to austere physical spaces.
"The limits on his rights have been very significant for a very long period of time," the barrister said.
"It's an affront to our shared humanity."
Lachlan Brown SC, representing the department, argued Marrogi's stringent conditions have been the result of his continued poor behaviour in custody.
He outlined how Marrogi was convicted of orchestrating drug importations over the prison phones, setting fire to his cell and assaulting prison staff.
Mr Brown told the court there were months at a time when Marrogi was performing well but then he would "relapse into non-compliance".
The stringent conditions were then implemented to protect himself, other prisoners and staff, Mr Brown said.
"The restrictions ... are significantly, if not entirely, in response to his own statements or behaviours," the barrister said.
The court was told Marrogi is facing fresh charges although the allegations were not detailed on Friday.
At a hearing in October, it was alleged officers located contraband items in Marrogi's cell, including a phone with a charger, three screwdrivers and 51 heart-shaped pills.
Ms Fitzgerald said the criminal charges would be contested so it was not appropriate for the civil court to speculate on the allegations.
The human rights case was adjourned to February 12 to give the parties more time to make submissions.
Justice Harris has already flagged it will be months before she hands down her decision.
