The driver accused of going on a deadly rampage down Bussell Highway in Capel in February was unable to attend his court hearing on Wednesday morning - having been left with acquired brain injury from the crash.
Shaun Southern was scheduled to appear in Stirling Magistrates Court but a fax from a social worker at Fiona Stanley Hospital was read out in his absence - confirming he was moved to a state rehabilitation facility as a result of his injuries and was unable to attend.
He has been at the rehab centre since March 20.
Mother-of-two Jenni Pratt, 61, of Geographe, died at the scene and her passenger, a 54-year-old woman from Busselton, was taken to hospital with serious injuries.
Mr Southern is charged with murder, acts or omission causing bodily harm or death and reckless driving in relation to the February 18 incident.
The father-of-two, from the Bunbury suburb of Usher, was charged during a bedside hearing as he recovered from serious injuries from the crash in hospital.
Police will allege Mr Southern drove onto the wrong side of the highway on a Saturday afternoon, forcing dozens of oncoming motorists to swerve or drive their vehicles at high speed into roadside ditches to avoid a collision.
Ms Pratt was returning from an outing with a friend when her RAV4 was hit head-on by the 4WD Mr Southern was driving. She died at the scene.
The matter was adjourned until April 26 for a mention only.