The girl, who cannot be named for legal reasons and is known only under the pseudonym WD, has been held in secure accommodation since being charged with the murder of a woman at a Footscray apartment when she was aged 12, in November 2023.
Prosecutors withdrew the charge in May 2024, citing no reasonable prospects of conviction due to doli incapax.
Doli incapax presumes children aged under 13 are incapable of understanding the wrongfulness of their actions and therefore cannot be convicted of a crime.
The girl remains under the care of the Secretary of the Department of Families, Fairness and Housing.
Her lawyer on Tuesday told a Melbourne court the girl has been going on outings which has been "really good" but continues to experience difficulties in her care program.
"In my conversations, she ... expressed her frustration with (the pace) of improvement and change," he said.
"The girl has asked 'why do I have changes in my workers?'"
He said she has told him of her desire to go to the gym, have more outside time after finding the curfew upsetting and wants to speak with Acting Principal Children's Commissioner Meena Singh without other people in the room.
She has told him about frustrations around rules being given but not followed up, including being told she could have a TV in her room for Christmas but she has not been told why this hasn't happened.
The child has also expressed a desire for "someone to come in to see her" for her schooling.
A lawyer for the secretary said a support teacher has been hired and is working with the child four times a week.
"Her schooling started in June. At the moment it is just virtual but it will become face-to-face sometime soon," the secretary's lawyer said.
Lawyers representing the girl, the secretary and the children's commissioner had been discussing the case's return date, with representatives of the girl and the children's commissioner requesting three months instead of six.
The court was told an investigation had begun into an incident involving the girl, with the judge describing what he heard as "extremely unsatisfactory".
"I'm sorry you had to go through that. No child should be spoken or treated like that," he addressed the girl.
The secretary pushed for the standard six months, offering to provide other parties with an update into the investigation within three months.
"Behavioural specialists have drawn a concrete link between the build-up to these hearings and (the girl's) behavioural issues," the secretary's lawyer said.
Her lawyer offered to have a support person with the girl to go over the proceedings with her straight away before he visits her to provide an update.
The judge has set a return date in December with a provisional date in August for an update on the case.
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