Child-killer challenges 40-year jail term

A man who tortured and murdered a toddler is facing 40 years of constantly fearing violence and intimidation from fellow inmates, a NSW court has been told.

Defence lawyer Chris Bruce SC stressed the "hyper vigilance" of prisoner Warren Ross and his onerous jail conditions, in his bid for a sentence cut in the Court of Criminal Appeal.

But Sally Dowling SC, for the Crown, urged the three judges to look at photos of the girl's horrific injuries, submitting the sentence could not be classified as either unreasonable or plainly unjust.

The 33-year-old former scrap metal worker was jailed for a maximum of 40 years, with a non-parole period of 30, for murdering two-year-old Tanilla Warrick-Deaves at her NSW Central Coast home in 2011.

He had only been going out with Tanilla's mother for a few months when he decided to toilet train the girl, subjecting her to prolonged and horrific abuse in the process.

He forced her to run laps, hit her and whipped her with various implements including an electric cord and his belt.

When she soiled herself, Ross took the little girl into the shower where she was bashed before being left in a pram for 36 hours, entirely ignored by the family before she was discovered dead.

Mr Bruce submitted the sentencing judge had not given sufficient weight to the onerous jail conditions faced by Ross, as a child-killer.

His fear of violence and intimidation would continue until he completes his sentence.

Submitting it was highly unlikely Ross would get parole after 30 years, the lawyer said he faced 40 years of hyper vigilance which might cease when he got out at age 68.

Ms Dowling stressed the horrific nature of the crime, describing the case as one of the most tragic to come before the court.

She referred to the girl screaming when Ross threatened to get the belt, which gave "some insight into the motivation and appreciation of the fear" he knew he could inflict.

"It was in the power of the applicant to save the child after he inflicted these injuries," she said, noting Tanilla was extremely ill in her pram for 36 hours.

The decision will be given at a later date.