Murderer Adrian Ernest Bayley's unsuccessful attempt to have his sentence cut will guide a review of Victorian legal aid funding for criminal appeals.
Adrian Bayley's 35-year minimum jail term was entirely appropriate given the vicious and callous nature of his murder and rape of Melbourne woman Jill Meagher, a court has found.
Bayley's failed publicly-funded bid to appeal his sentence has prompted a review by Victoria Legal Aid (VLA), with the body now considering more stringent tests and limits on which cases it will support.
Ms Meagher's husband Tom Meagher slammed the appeal bid, which was rejected in the Victorian Court of Appeal last month, as a waste of public money.
In reasons published on Monday, Chief Justice Marilyn Warren, Justice Paul Coghlan and Justice Marcia Neave said the sentence was entirely within an appropriate range given the "callous" circumstances of Ms Meagher's killing.
"These included the viciousness of the attack being a stranger rape and subsequent killing carried out by a comparatively large man on a small woman," they said.
"The applicant was a violent sexual predator who killed his victim."
The judges rejected Bayley's lawyer's arguments that the sentence imposed should have not been in the same category as Melbourne CBD killer Christopher Wayne Hudson and gangland killer Carl Williams.
It took just 10 minutes for the appeal bid to be thrown out, but the judges said this was because most submissions had already been made in writing beforehand.
VLA acting managing director Meagan Keogh said the court's reasons would guide a review of which cases should receive funding.
"Even an appeal that is dismissed provides guidance to others that the trial judge got the sentence right," she said on Monday.
"This helps lawyers advise other clients about the possible outcomes of their case."
However, Ms Keogh said VLA would not use emotion to decide which appeals it would fund.
"We must adhere to objective processes and cannot be influenced by how we might feel about the individuals involved," she said.
"If we did not fund legal representation in appeals, courts would be clogged with people representing themselves and unable to understand complex law."
Shadow attorney-general Martin Pakula said the real issue facing VLA was a lack of resources.
"This review will not fix the chronic underfunding of legal aid," he said.