Baby murderer Harley Hicks will spend the next 32-years behind bars after three court of appeal judges rejected his claim that the sentence was excessive.
Hicks, 22, was jailed for life with the 32-year minimum for the brutal bashing murder of 10-month-old Zayden Veal-Whitting.
He switched off Zayden's baby-monitor and bludgeoned him 33 times with a baton during a burglary at a Bendigo home in June 2012.
Hicks appealed against the sentence, with his barrister David Hallowes arguing a lack of premeditation and Hick's youth made the minimum term excessive.
But Victorian Court of Appeal Justices David Ashley, Simon Whelan and David Beach ruled the sentence was appropriate.
"This was a killing of the gravest kind, by a man with a prior criminal history, who had little prospects of rehabilitation, who was not remorseful, having a lack of compassion and empathy for others, and from whom the community required protection," Justice Ashley said on Wednesday.
"It was a grave step to impose life imprisonment on a man so young, and then to fix a long non-parole period.
"But we are unable to see any flaw in his Honour's synthesis of the relevant circumstances."
Zayden's mother, Casey Veal, said Hicks' term was nothing compared with her family's grief.
"My son never got to be an adult. His older brother is going to grow up into an adult and have his own problems adjusting ... missing his little brother who's not there to send him off to school every day," she said outside court.
"We think the decision was right, now as a family we can try to become normal again."
Hicks' defence argued his crime differed from those of other child killers, such as killer-fathers Arthur Freeman and Robert Farquharson, who received similar sentences.
"Any of the cases where children are killed are distinguished by circumstances absent in the applicant's case: revenge against perceived wrongs by a spouse, and the breach of that fundamental social duty, that of a parent to protect a child," their written submission read.
"Each of those features make those cases more heinous."
Mr Hallowes said that Hicks' youth, aged just 19 when he killed Zayden, in combination with the lack of premeditation, made the minimum term manifestly excessive.
Prosecutor Susan Borg said Justice Kaye placed the crime in the worst category of murder for reasons other than premeditation and revenge.
Hicks took the baton with him for the purpose of protection or engaging in violence, and did so against a "soft target", she said.
Hicks will become eligible for release in 2044 when is 51 years old.
