AS MANY as 20 Victorians have been killed by serial offenders who should have been in jail over the past decade.
For those victims, most of them young women, the latest review of the state's justice system, announced by Victorian Premier Daniel Andrews on Monday, comes too little too late.
Mr Andrews has introduced a system of on-call magistrates who will be available for decisions 24 hours a day as part of an overhaul of the state's Bail Act.
The change came after revelations Dimitrious "Jimmy" Gargasoulas, who allegedly killed five and injured 37 in Friday's Bourke St massacre, was granted bail against the advice of Victoria Police five days before the attack.
Mr Andrews also promised a shake up of the system in April last year in response to the 2015 murder of schoolgirl Masa Vukotic by convicted serial rapist Sean Price while free on bail, commissioning Supreme Court Judge David Harper to conduct a review.
The 2016 Harper Review saw changes to the management of serious sex offenders, who are now supposed to be monitored by a separate "public protection" agency and required to under early intervention treatment.
That overhaul came on the heels of the 2014 Callinan Review, a scathing report on the inadequacies of Victorian parole laws in response to the 2012 rape and murder of Jill Meagher by Adrian Bayley, who was on both parole and bail.
Somewhere in between, a coronial inquest into the death of schoolboy Luke Batty by his homeless father Greg Anderson, who had been bailed to a motel - against police advice - on child pornography charges, found there had been a "system failing" of the "bail process".
None of these reviews prevented the release of Gargasoulas, who was bailed on January 14 on unrelated assault charges and there's no guarantee the current one will prevent future tragedies.
The strongest proposal comes from the The Police Association of Victoria, who wants people accused of serious and violent crimes to be automatically refused bail.
They include offences such as armed robberies, carjackings, serious assaults and home invasions.
Association assistant secretary Bruce McKenzie has also called for bail justices to be scrapped.
According to the Herald Sun, bail justices feel pressured to grant bail because Victoria's prisons are overcrowded.
Victoria Police Association boss Ron Iddles told ABC's 730 program we shouldn't wait for tragedies to happen before reviewing the laws.
"If you go back to Hoddle Street (massacre) or if you go back to Gillian Meagher, there were issues around parole and there was a review of that but sadly it's a tragic event that highlights we need to have a change in the Bail Act when we've been talking about it for some time and we should've had action made there before," he said.
Mr Iddles thinks the night court announced by Mr Andrews would be a good preventive measure because magistrates are more experienced then bail justices.
"I'm not saying this bail justice got it wrong, he would have heard the police side, which opposed it, he would've heard the side from the accused person and he made a decision based on the best knowledge he had of the Bail Act," he said.
PEOPLE MURDERED BY OFFENDERS ON BAIL OR PAROLE IN VICTORIA
Masa Vukotic, 17
Convicted serial rapist Sean Price stabbed Doncaster schoolgirl Masa Vukotic 49 times in a frenzied attack in March, 2015 before raping a woman in a nearby bookstore.
Price, now 33, had been on bail for issuing death threats to guards during a stint at Port Philip prison. He also told the guards: "When I get out I'm gonna ... slit kids' throats."
Price, who had a long history of sexual violence against women, was under a court supervision order.
He was not on parole because he had served all his time in jail - known as "maxxing" - and had to be released.
"Our justice system failed Masa Vukotic," Premier Daniel Andrews said at the time. "It failed her family and friends. It is a tragedy that must force change.
"That Sean Price was free and largely unmonitored in our community was a catastrophic failing of the criminal justice system."
Elsa Corp, 26
Elsa Corp was beaten, slashed with broken glass and strangled with an electrical cord by David Patrick Clifford at a Melbourne hotel in 2010.
Clifford, who was in a drug induced psychotic rage, was on parole for drug offences and on bail after being charged with the violent assault of two men in 2008.
Luke Batty, 11
Luke Batty was bludgeoned to death at a Tyabb cricket oval by his father Greg Anderson on February 12, 2014.
At the time of the attack, Anderson was homeless and on bail for child pornography charges.
Senior Constable Paul Topham, who arrested Anderson in January 2013, said he was "astounded" when he made bail, having been unable to provide a fixed address.
Anderson was bailed to a motel and later applied to change conditions to include his new address - his car.
Senior Constable Topham said it was a common, continuing problem for offenders with no fixed address.
"I was astounded that he still got bail based on the information that we had," he told a coronial inquest into Luke's death.
Sarah Cafferkey, 22
Judge Ian Gray, who conducted a coronial inquest into Ms Cafferkey's death, said Hunter posed a real risk to the community when his parole period ended in 2012, 11 days before he killed her.
But the Adult Parole Board was not made aware of a report that made it clear Hunter needed substantial further intervention, allowing him to "play the system".
The parole was in relation to the 1986 murder of an 18-year-old girl.
"Because of his unchanged attitude towards violence, in particular violence against women, Hunter posed a real risk to the community, both when he commenced his parole and at the end of his parole period," Judge Gray said.
Judge Gray said Hunter's case workers were overly prepared to accept his self-assessment of his progress on parole and did not bring sufficient rigour or scepticism to the task.
Jill Meagher, 29
Bayley, 44, was paroled after serving a sentence for a series of violent rapes when he was arrested in over the assault of a man.
He pleaded guilty to the assault, but appealed the three-month sentence handed down by a magistrate, and was not sent back to prison by the Parole Board. Corrections Victoria also recommended that Bayley not be imprisoned while the appeal was pending.
Retired High Court Judge Ian Callinan was commissioned to review the parole system following Ms Meagher's murder.
"It is no answer to say that he had an appeal pending. It was an appeal against sentence only. Bayley was therefore both on parole and on bail when he raped and murdered Ms Meagher,'' Mr Callinan said in his report, released August 2013.
Evan Rudd, 29.
Evan Rudd was killed by serial offender Richard Stephen Devries during an argument over a car parking spot in Moe in 2011.
Devries had 80 convictions dating back to 1991 and was on parole for assault at the time.
Raechel Betts, 27,
It was his third murder.
Coombes pleaded guilty to strangling Ms Betts to death and then dismembering her body after the pair argued in bed at the Phillip Island home of friend Nicole Godfrey.