A man accused of murdering a woman in a head-on crash near Capel, in Western Australia's South West, in February may never be able to stand trial because he is brain damaged.
Shaun Southern, 45, appeared in court for the first time over the crash that killed 61-year-old Jeni Pratt and seriously injured her passenger.
Mobile phone footage recorded by witnesses showed his four-wheel drive swerving into oncoming traffic on the Bussell Highway, before it collided with Ms Pratt's SUV.
Ms Pratt died at the scene.
Southern was also seriously injured and, until recently, was being treated in hospital.
He is facing charges of murder, acts causing bodily harm and reckless driving.
Southern is now in Casuarina prison and appeared in the Stirling Gardens Magistrates court in a wheelchair via video link.
His lawyer, Kathryn Heslop said her client is not currently fit to plead to the charges against him, because he is suffering from brain damage.
She requested that further tests be ordered, saying "the issue is whether he will become fit to stand trial".
Ms Heslop said if it is determined he is not fit, they may seek to "quash the indictment" in the Supreme Court.
Southern was remanded in custody until he appears in court again in August.
