A murderer and rapist has had his parole chances frozen until 2014.
Peter Howse was jailed in 1982 for killing his partner Susan Keenan and later given preventive detention for committing three sex attacks while on parole.
Howse denies his sexual offending, but has said he is not against undertaking some general counselling in relation to the murder.
The Parole Board says Howse has made no progress at all since he last sought release a year ago.
Howse's lawyer says the three-year parole stand-down would get in the way of an independent psychological risk assessment for him and affect his mercy plea to the Governor-General.
But the Parole Board has rejected both arguments, saying Howse is an untreated sex offender and there has been an absence of significant change for him.
His mandatory annual hearing has been put on hold until 2014.