A post-mortem conducted on Ms Bates was unable to determine her cause of death, a police spokesperson said. 

Police said detectives were awaiting the results of further testing as they continue their investigation into her death. 

Torney has been accused of assaulting Ms Bates between Saturday and Tuesday, court documents stated.

He faced Shepparton Magistrates Court on Friday, where prosecutor Charles Moffatt said police will allege he was responsible for a serious assault and causing injury.

Torney's lawyer Kyle McLaughlin said his client was Aboriginal, withdrawing from drugs and asked for his case to be dealt with in Cobram.

However, Magistrate Peter Dunn said it would be better handled at Shepparton, as that court had better custody facilities.

Mr Dunn said Torney would have to sit in a police van to wait for his matters to be called if it stayed in Cobram, whereas in Shepparton he could walk through an internal passage into the court room. 

Torney did not apply for bail and the magistrate remanded him in custody to next appear at the Shepparton court via video link on May 21.

Ms Bates has been remembered as a much-loved member of her family who was always helping people and spent her life dealing with health issues, using a mobility scooter to get around.

"Despite all her health challenges she had the biggest heart of anyone we know," her family said in a statement published on social media.

"It’s tragic that her big heart has led her to a friendship with a man who wished her harm. No one deserves that."

Torney was in 2016 acquitted of murdering a toddler, after the two-year-old girl's beaten body was discovered in the roof cavity of a Mildura house.