Justin Blake Smith's 47 plants were uncovered under his house by police who were called to the house over reports he had been shot.

In a sentence hearing before Albury Local Court, defence lawyer Graham Lamond said Smith suffered compression of his neck in the fatal crash, for which he wasn't released from jail until 2015.

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Amanda Bowen, 21, was a passenger in Smith's car when he crashed in Atkins Street, South Albury, on September 21, 2009, after taking a corner at 92km/h when driving with a blood-alcohol level of 0.188 per cent

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Another crash, just last December, had exacerbated these injuries, Mr Lamond said.

Smith, who has been in jail in protective custody since January 10, was to have been sentenced on Tuesday, but magistrate Rodney Brender decided instead to delay his decision until next Tuesday.

He previously pleaded guilty to several charges including use, consume or waste electricity without authority, possess or use a prohibited weapon without a permit, goods suspected of being stolen found on premises and cultivate a small and indictable quantity of a prohibited plant.

A more serious drug charge related to growing cannabis was dropped following negotiations between the Director of Public Prosecutions and Smith's defence.

Nevertheless, DPP representative Mary-Beth McFarlane told Mr Brender it was important to note that the number of plants fell only just short of the 50 required to meet the more serious charge of cultivating an indictable quantity.

The court previously heard how a routine sweep by police after they were called to his house when he was shot following a dispute with two other men on the evening of January 5 uncovered the secret room under his house.

Police also found a loaded crossbow and several stolen bikes and discovered that Smith, 40, had bypassed his electricity meter box.