The Wodonga Magistrates Court began hearing evidence in the case on Wednesday, with a Wodonga hospital worker saying several red flags were raised when the mother and 23-month-old boy presented on Christmas Day, 2019.

The court heard the mother had possibly thrown the boy over a couch, but the cause of the injuries is in dispute.

It's alleged the incident occurred in the early hours of December 22 of 2019, but the boy wasn't taken to Wodonga hospital until December 25.

Police allege the serious injuries caused by the mum were reckless, rather than deliberate.

The defence does not dispute an assault, but the cause of the injuries and the mother's state of mind is disputed.

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Dr Maryanne Lobo examined medical records at the request of Wodonga investigators.

The court heard one right arm bone fracture involved a significant dislocation and wire was required to repair the fragment.

X-rays were tendered to the court.

Dr Lobo noted bowing was also visible in the boy's right arm, which had four fractures.

"Normal playing and normal handling of children, with children of this age, should not cause such a combination of fractures," she said.

The doctor told the court a fall was unlikely to cause the number and severity of the fractures.

Nurse Yvonne Hargreaves spoke to the injured boy and his mother when they presented for treatment on Christmas Day.

She said the boy had a swollen arm and the mother gave several versions of what might have occurred.

"The delay in presentation is a bit of a red flag for us," she said.

The boy's grandfather said he had been unsettled while in his care before Christmas.

He said the mother mentioned that the boy had injured his arm.

The hearing is due to run for three days.

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