A Cobram man remains in custody after allegedly attacking a woman, who was later found dead inside her home.
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Charges sheets allege the victim may have been assaulted up three days before her body was found.
Police allege John Torney, 39, intentionally caused injury to Emma Bates, 49, sometime between April 20 and April 23.
Her body was found in her Campbell Road Home at 2.15pm on April 23.
Torney is accused of breaching intervention orders in the matter, and faces multiple assault related charges.
Magistrate Peter Dunn asked a police prosecutor in Shepparton court on Friday, April 26, what the case was about.
The court heard that at this stage the allegation was of "a serious assault" causing injury, and that Torney wasn't seeking bail.
No charges of murder or manslaughter have been laid over Ms Bates' death.
Lawyer Kyle McLaughlin was asked about custody management issues, and replied that his client was "withdrawing from a drug of dependence", but that he didn't know what the drug was.
Torney, who lived next door to the late woman, faces 13 charges and has other matters listed in Cobram court on June 3.
Questions were raised about whether the appropriate venue for the charges relating to Ms Bates was in Shepparton on Cobram.
Mr Dunn remanded Torney in custody, with the 39-year-old to return to Shepparton court on May 21.
Torney raised his middle finger to those in the body of the court as he was led out by two police officers.
He did not speak during the court hearing.
Police appeared to leave the door open for further developments in the case, with a statement issued after the court proceedings.
"Cobram Crime Investigation Unit detectives are continuing to investigate the death of a 49-year-old woman in Cobram earlier this week," a spokeswoman said.
"A postmortem was conducted and at this stage, the cause of death has been unable to be determined.
"Detectives will await the results of further testing and continue with their investigation."