Schoolgirl killer Sean Christian Price has been denied any chance of walking free from prison before 2053 for the brutal slaying on a Melbourne walking track four years ago.
Masa Vukotic was 17 when she was murdered by Price, who is now 34 and will be in his 70s before he's eligible for release.
The killer made a rude gesture as three Court of Appeal judges on Friday told him there was little prosect his appeal against his sentence would succeed, or that the minimum 38-year term would be reduced.
Price, who represented himself and appeared by video link from prison, said he was to blame for the frenzied attack on the Doncaster teenager, but added he didn't want to plead guilty and now wants to wait until "public anger dies down" to argue he was mentally impaired.
He also denied raping a woman in a Christian bookshop the day he handed himself over to police for the murder. That woman was in the courtroom on Thursday.
Justice Lex Lasry sentenced him to life in prison, with the prospect of parole only because of his guilty plea.
But justices Simon Whelan, Stephen McLeish and Terry Forrest raised questions about a sentence handed down a year later by Justice Meryl Sexton in connection with the bookshop rape.
The rape breached a 10-year supervision order after Price, then 19, carried out a series of sexual attacks in suburban Melbourne in 2003, attacking three women on the street and another in front of her children after following her home.
Justice Whelan said they were considering the possibility Price was double sentenced for the rape, given Justice Sexton's breach sentence appeared to quote verbatim from the rape sentence.
Prosecutor Diana Piekusis SC and Price have been given a week to make formal submissions.
If he is found to have been double sentenced, Price could have that four-year-and-nine-month sentence, or the additional three years tacked onto his non-parole period, reduced.
He is currently not eligible for parole until he's 72.
He claimed he only pleaded guilty because he was bashed and beaten while on lockdown in prison, left with blood clots and a split skull.
"I wanted to withdraw my plea, even before we (got) to sentence," he said.
"I admit I'm guilty, not of the rape, but of the murder of Masa Vukotic, but in future I want to argue I was mentally impaired."
He also suggested Justice Lasry had erred in sentencing him "because maybe the horror of what he seen might have affected him".
"I understand what I did was bad but I was mentally ill," Price added.
"Later I can appeal when the public anger has died down and they can see I never got a fair trial."
A psychiatric report at the time found he was mentally ill and had a personality disorder, but was not mentally impaired.
Australian Associated Press