The Wodonga Magistrates Court this week heard Ian Edward Hoare is probably unable to be rehabilitated for his violent behaviour.

The 60-year-old, who lives in public housing on Dempsey Place, bashed his wife Sally Anne Lorraine Hansen to death at Seymour in November, 1997.

A forensic pathologist at the time said the late woman had the worst bruising he had ever seen.

It was likely caused by Hoare repeatedly smashing her head into the ground.

Hoare attacked her with such ferocity, her scalp separated from her skull as she was dragged by her hair.

She had 15 bruises and cuts on her face and neck, cuts in her mouth, 24 bruises on her arms, and deep brain damage which tore the links before the two hemispheres.

Hoare was jailed in 1999 for a minimum of 12 years with a 16-year maximum.

He has continued his abusive ways, and was jailed in Albury Local Court in 2017 for a serious domestic violence assault and stalking, then placed on a corrections order for further domestic violence offending in the court.

He has also served jail time for breaching family violence orders in 2015 and making threats to kill in 2014, with a criminal history dating back to the 1970s.

Hoare was recently arrested at his home in Albury and transferred to Wodonga for stalking his ex-partner and persistently breaching a family violence intervention order she had taken out against him.

Hoare made a large number of abusive phone calls to the woman over several weeks, starting on December 18 last year, despite being banned from having any contact with her.

He left 55 abusive voice messages on her phone over a 14-day period.

Magistrate Ian Watkins said Hoare blamed the victim for the relationship breakdown.

"The behaviour is aggravated by the fact it was in breach of an order," he said.

Mr Watkins told the 60-year-old he appeared to have "no prospects of rehabilitation at all and it seems you have little insight into your behaviour", and had shown no remorse.

It was important to protect the victim and the community, the magistrate said.

A report from psychologist Susette Sowden noted "intervention will not produce any substantial improvement".

Lawyer Mario Vaccaro agreed that "rehabilitation probably isn't an aspect" and asked that Hoare be released given the time he had already served.

He said Hoare had been making plans with the woman when they broke up.

"This was a shattered dream for him," he said of the breakdown.

"It had a very substantial impact on him."

The pair were together for about a decade.

Mr Vaccaro said his client could become institutionalised.

"If indeed he's not already," Mr Watkins replied, noting jail was the only option.

Mr Vaccaro asked for a short sentence.

His client will have to face NSW court for breaching an intensive corrections order after completing his sentence in Victoria.

The court heard Hoare had sent some of the message to the victim from NSW.

Mr Vaccaro said the 60-year-old had spent more than half of his life in jail.

Mr Watkins jailed Hoare for five months.