Graham James Kay was released on parole in 2023 after serving two decades behind bars for sexually-motivated attacks, including violently raping several women in Sydney's north during the 1990s.
Dubbed the "North Shore Rapist", Kay was released for those crimes in 2015 but sent back to jail after stalking and assaulting a woman in Sydney's city centre in 2022.
One psychologist diagnosed Kay with having a "sexual sadism disorder" that affects his risk of repeat offending.
Supreme Court Justice Hament Dhanji on Thursday ordered Kay be subject to an extended supervision order for a period of three years for the protection of the community.
The orders can be imposed by the court on convicted criminals whose sentence has expired but are still deemed to present an unacceptable risk of serious reoffending, necessitating long-term monitoring.
Justice Dhanji found there was a low risk of Kay committing a serious offence, but a much greater risk he would commit an offence similar to one in 2022, when he stalked a 20-year-old woman back to her apartment and put his hands up her dress before fleeing.
"Despite the relatively low risk that the defendant will commit a serious offence, the consequences should he do so are likely to be dire," the judge said.
Under the conditions of the order, Kay will be under strict conditions and monitoring by an appointed officer as well as constant electronic tracking.
As well as diagnosing Kay with sexual sadism disorder, forensic psychologist Marcelo Rodriguez found he was vulnerable to perceptions of abandonment within intimate relationships, significantly increasing his risk of committing a sexual offence.
In the circumstances of the 2020 offence, Kay reported that he had earlier become friendly with a woman he met at a Buddhist meditation group.
Kay said he had received a letter from the woman suggesting she did not want to continue the friendship, which he said "crushed" him and drove him to commit the crime.
The attacks committed between 1995 and 1996 were Kay's most violent and involved him approaching lone women or girls in public places at night, threatening them, demanding money and sexually assaulting them.
In some circumstances he held a knife to the victim's throat, forced a gag into their mouth or tied their hands and dragged them to a nearby secluded location where the assaults took place.
Kay breached an extended supervision order after his release from jail in 2015 by failing to disclose an intimate relationship or obtain permission for a sex worker to spend time at his home.
Four days before being sentenced for the breach, Kay assaulted a 16-year-old girl who was working at a supermarket, for which he received a 15-month conditional release order.
Kay's history of disturbing behaviour towards women stems back to 1971, followed by convictions for indecent assault in 1975, peeping and prying in 1983 and 1987, and breaching a domestic-violence order in 1995.
1800 RESPECT (1800 737 732)
National Sexual Abuse and Redress Support Service 1800 211 028
