Omar Haouchar, 32, was arrested in January over an alleged conspiracy to murder a rival gang member outside the Day St police station in Sydney’s city centre.

His barrister told a Supreme Court bail hearing that a person close to Haouchar had put forward a cemetery as security to support his release application.

”I’ve never seen a cemetery offered as security before,” Justice Ian Harrison told the NSW Supreme Court today.

The valuation of the cemetery was uncertain because, unlike its surrounding property, it was not available for subdivision, barrister Ertunc Ozen SC said.

But it was estimated to be worth millions of dollars.

Haouchar, who appeared in court via a video link from the Goulburn supermax remand centre, was previously denied bail in February.

Since that time, Ozen said further documents had been tendered to the court by prosecutors, detailing evidence against his client.

Associates of the Haouchar crime network allegedly used encrypted app Threema to discuss murdering 30-year-old Andre Kallita in December 2023.

Prosecutors claimed that Haouchar was using the handle “Invisible” in an encrypted group chat titled “URGENT”.

The murder plot involved a lookout, waiting to see Kallita report to the police station for bail, alerting two shooters waiting close by, according to a police statement filed with the NSW Supreme Court.

But Ozen said there was insufficient evidence to prove Haouchar is Invisible.

“The Crown simply cannot tie Invisible to this applicant,” he told the court.

“This is the crux of the crown case, and without that attribution, the crown case fails.”

He also argued that since Haouchar’s transfer to supermax, his ability to communicate with his legal team had been limited and this would result in delays to court proceedings.

“The conditions of custody make it nearly impossible for him to prepare for this matter,” Ozen said.

Crown prosecutor Rebecca Stefani opposed bail, arguing Haouchar posed a risk of committing further offences and attempting to leave the state.

She told the court he had spent 11 years in custody for a slew of offences. 

These included reckless wounding, aggravated burglary and directing the activities of a criminal group.

The Haouchar syndicate, largely operated by leaders based in Lebanon, has been tied to $1.5 billion in cryptocurrency transactions and various firearm, drug, tobacco and money-laundering offences, police said previously.

Justice Harrison will make his decision on the bail application after further submissions have been filed.