A murderer who killed another inmate after being jailed for life will study counselling while behind bars, but will not be allowed to practise on other prisoners.
Violent double-murderer Craig William Minogue, 52, launched legal action against Correctional Services Commissioner Jan Shuard, claiming he was being prevented from completing a diploma he started in 2013.
The Victorian Supreme Court has now heard Corrections Victoria cannot prevent him from receiving the distance education course material but Minogue will not be able to use other prisoners for the practical part of the course.
A relative paid for Minogue to take the $3190 diploma while he is serving his sentence for the 1986 Russell Street police complex car bomb attack that killed Constable Angela Taylor and injured 21 others, court documents show.
After he received a letter in November advising him to cease studying, he took the matter to court.
A lawyer for the commissioner said while Corrections Victoria would not practically support Minogue, he could not be prevented from receiving correspondence from the training organisation.
"Corrections facilities cannot stop his mail," Claire Harris, for Ms Shuard, said.
"It will be stopped of censored only when required under The Act."
She gave the example of a hypnosis course, which could be "misused" in the prison.
"One prisoner wanted to study a review of terrorism course and that was not permitted," she said.
The Australian Institute of Professional Counsellors course involves a practical element that Minogue will be unable to complete.
Practising counselling on other prisoners would not permitted, Ms Harris said.
Minogue did not attend court for the hearing.
While in custody, Minogue also killed inmate Alex Tsakmakis, who was beaten with gym weights hidden in a pillow case at Melbourne's Pentridge Prison in 1988.
His sentence carries a minimum non-parole period of 28 years and he is due to be eligible for parole this year.
Minogue has previously taken legal action in the High Court claiming the food available in prison breached his right to a varied vegetarian diet.