Hoddle Street mass murderer Julian Knight has allegedly been involved in a prison assault that left a prisoner in hospital with a broken jaw.
Corrections authorities and Victoria Police have investigated the January 15 assault that left a prisoner with serious injuries, the Victorian Supreme Court heard on Friday.
The victim spent at least eight days in hospital, according to a court judgment.
"I was informed during the hearing that the prisoner, the subject of the alleged assault, remained in hospital and there was a police investigation of the incident leading to his injuries," Justice Jack Rush said in the judgment.
Knight, who has been in solitary confinement since the assault, told the court the victim fell over.
Prison authorities allege that during a meeting Knight said people slip over in prison when they are caught stealing.
He then said he was referring to karma, the court heard.
Police interviewed the victim on Thursday and the police investigation was now complete, the court heard.
Police have referred the matter back to prison authorities.
Knight laughed loudly and banged his handcuffed hands together as he tried to clap on hearing the news.
Knight was in court because he is seeking to file a writ of habeas corpus against his detention in high security and solitary confinement.
Justice Rush refused Knight permission to issue the writ.
Knight has been declared a vexatious litigant and must seek court permission before issuing a writ.
Justice Rush said he had difficulty understanding what Knight sought by issuing the writ, apart from saying he wanted relief of some nature from the circumstances he was in.
He said Knight's complaint concerned an administrative process in the prison.
"The consequences of that decision, ie removal to a high security unit and loss of privileges, do not provide a basis for the issuing of a writ of habeas corpus," Justice Rush said.
"The constraints of imprisonment should not be confused with the nature of imprisonment.
"Based on the authorities I have referred to, it can be said the writ of habeas corpus cannot apply to a prisoner lawfully detained."
Knight, who killed seven people and injured 19 during a shooting rampage in 1987, was sentenced to life in prison with a 27-year non-parole period.
He is eligible for parole in May, but Victorian Premier Denis Napthine has vowed Knight will never be released while he is premier.
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