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Gordon Marshall, found guilty of the 1985 murder of Constable Lyncon Williams in Blair Athol, has been sent back to prison for violating his parole terms.
Marshall, who was 17 at the time of the crime, received a life sentence, but has been in and out of jail since then.
A court heard today that Marshall was granted parole in April last year and moved to live at the pre-release centre.
However, it only lasted until August, when he breached his conditions, which include a ban on drugs and alcohol.
Marshall is characterized as a habitual offender. In 2016, he fled a Northfield day release center and was later captured near the District Court, where he claimed to possess explosives.
Marshall has now made another request for release. The court has ordered a report before it makes a decision next month.