Sokaluk was arrested on Friday and charged with one count of arson causing death and one of lighting a bushfire in connection to a blaze that started in the town of Churchill, located 140km southeast of Melbourne, the state capital.

Police have said they believe several other fires were deliberately lit, although Sokaluk is the only suspect to so far face charges.

Sokaluk faces a maximum sentence of 25 years in prison on the first charge, and 15 years on the second.
 
He was also charged with possessing child pornography, which carries a 5-year maximum sentence.

Officials have previously said the Churchill fire killed at least 21 people, although they cited only 11 deaths in court.

They did not immediately explain the discrepancy.

Difficult to prove

According to experts, arson in wildfire cases are difficult to prove, partly because different bushfires often join one another, making it hard to link a fire set by an arsonist with the blaze that eventually kills people.

The Churchill fire was one such combination of blazes.

Extremely hot, dry and windy conditions fanned dozens of fires into raging infernos that reduced entire towns to ashes.

The confirmed death toll is 181 but is expected to exceed 200. More than 1,800 homes were destroyed and 7,500 people have been internally displaced.

In Monday's brief hearing, Helen Spowart, the defence lawyer argued that Sokaluk's name should not be revealed due to an unusual level of public anger and disgust over the case.

John Klestadt, the magistrate, agreed to ban the publication of photographs of Sokaluk or his address, but not his name.

"Those suspected of vigilantism would not be prevented from behaving in an abhorrent way simply by suppressing his name," Klestadt said.

Earlier on Monday, Christine Nixon, the state police commissioner, said security around Sokaluk would be high, and urged Australians to let the justice system do its work.

"We hope that we don't have to deal with a gang of people who are angry and concerned about this arrest - we know people are," she told reporters.

"We will make sure he is protected and can go before the justice system, as he should, and be dealt with through that process."