Kevin John Carr received what was Victoria's first indefinite sentence in 1995 after he raped the elderly woman at Spencer Street train station in 1994.
He had committed the rape about a month after being released from prison.On Thursday, Victorian County Court chief judge Michael Rozenes said he was satisfied Carr still posed a danger to the community.
Carr had accumulated 57 prior convictions in more than 18 years, including jail terms for five separate incidents of sexual assault or rape between 1979 and 1990.
"I am satisfied to a high degree of probability that he is still a serious danger to the community," he said in his ruling.
Mr Rozenes also said serious questions had been raised about Carr's willingness to take part in a sex offender's program.
Carr will be able to apply for another review of his indefinite jail in three years.
"25% of all sex offenders re-offend within 15 years"
.........Sarah Tofte
.........Sarah Tofte
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