A forensic anthropologist says it is impossible to know whether a 33-year-old Victorian mother was already dead when a man shot her five times in the head.
Soren Blau told the Supreme Court on Monday the gunshot wounds in Simone Quinlan's head occurred perimortem, that is, around the time, shortly before or shortly after death.
Wayne Marmo dumped Ms Quinlan's battered body in a mineshaft near Bendigo in August 2015 before setting it on fire.
Marmo is on trial for her murder, which he denies.
Dr Blau told the court Ms Quinlan's head, torso, and pelvis and leg were recovered in three separate parts.
She said the gunshot wounds may have occurred after Ms Quinlan was already dead but because of the lack of soft tissue to examine, it was impossible to determine how long afterwards.
Marmo's defence lawyer Scott Johns previously argued that Ms Quinlan was most likely dead by the time she was shot.
He said her murderer was her boyfriend Brendan Neil, who beat her up in a prolonged attack before she was driven away and her body dumped.
He said Marmo was instead guilty of attempted murder.
On Monday, a witness who can only be identified as DJ, said he'd witnessed Neil hitting Ms Quinlan in the head with a hammer and wrapping her face with black duct tape.
AAP