Michael Cardamone became the first killer without a prior murder conviction to be handed a life sentence without the chance of release, when Justice Lex Lasry jailed him in August 2017.

The murder of his 49-year-old neighbour was "extraordinarily vicious, callous and thoroughly unprovoked", the judge said at the time.

Cardamone's lawyer Dermot Dann QC agreed in the Court of Appeal on Thursday that the murder was horrific. He's not contesting the life sentence.

But Mr Dann is challenging the failure of Justice Lasry to mention he was considering an indefinite prison term.

That meant Cardamone's lawyer at the time wasn't given a chance to consider and potentially address the court on similar NSW cases in which parole had been denied.

He also argued inadequate weight was given to Cardamone's guilty plea, questioning the incentive for people to plead guilty if there was no visible discount for doing so.

Appeal Court president Chris Maxwell said the sentencing remarks included a "powerful catalogue of descriptions" of Cardamone's acts and his prior history.

He said it wasn't often a judgment included phrases like "thoroughly unprovoked", "horrifyingly callous" and a description of seeking to cause "terror and suffering" in a victim.

"And that's just in the first paragraph," Justice Maxwell noted.

"It's not difficult to see why this judge has done what he'd never done before."

Director of Public Prosecutions Kerri Judd QC said nothing in the law required that a person denied a parole must have a prior conviction for murder.

She said Cardamone had a significant criminal history, pointing to his parole status after being released from jail six months before the murder, after serving time for raping a 15-year-old girl.

He also made elaborate attempts to escape responsibility for the killing, including attempting to arrange the murder of a witness.

The judges will give their decision on allowing the appeal at a later date.

Ms Chetcuti was attacked while in the vegetable garden of her rural Whorouly home in January 2016.

She was sedated with a horse tranquilliser, injected with battery acid and bashed while being held prisoner for hours by Cardamone, before being burnt alive in remote bushland.

He pleaded guilty to her murder.

The appeal comes months after Ms Chetcuti's former husband Tony Chetcuti lodged a legal claim for damages from the state, claiming Cardamone wasn't properly supervised on parole.