Record numbers of early voters missed out on important election day sausage sizzles and interactions with candidates, lawyers for a candidate disputing the validity of Victorian election result have argued in court.

Palmer United Party (PUP) candidate Maria Rigoni has taken the Victorian Electoral Commission (VEC) to the Supreme Court, arguing that the number of early votes allowed before the 2014 election rendered the results invalid.

Ms Rigoni failed to win an Upper House seat at last November's state poll.

More than a million people voted before the November 29 election day, amounting to more than 31 per cent of all voters.

Ms Rigoni's lawyer Dr Anton Trichardt argued it was important for voters to "see the sausage sizzle" and "listen and engage" with candidates on election day for the results to be valid.

The early votes were not properly declared in line with the Electoral Act, and they put minor party candidates at a disadvantage because those casting an early ballot were not in a position to properly assess their candidacy, Ms Rigoni said.

Dr Trichardt said the case was "apolitical" and Ms Rigoni was not acting for selfish reasons.

He told the court that the case brought on by his client was not about her failing to win a seat, or disputing the vote count.

He said Ms Rigoni was acting in the broader public interest of wanting to find out whether or not the VEC fulfilled the requirements expected of it to properly uphold the Electoral Act.

Ms Rigoni, who has previously represented herself in court, has not been supported by the Palmer United Party in taking legal action.

"This is not a petition about a particular political party," Dr Trichardt said.

"This is apolitical."

No proof earlier voters 'unable' to vote on election day

Ms Rigoni's barrister said interpretation of the word "unable" in the context of whether or not early voters were truly unable to vote on election day itself, would be critical to his client's case.

Dr Trichardt also told the court the VEC had "no hard evidence" that proper declarations were made by people voting early at pre-poll centres.

The process was "not compliant with state rule" and "not fair" he said.

The court heard evidence from individual pre-polling centres would be heard during the trial.

Lawyers from the Victorian Government Solicitor's Office, acting on behalf of the VEC, have previously called on the court to throw the case out.

They have argued the case was "an abuse of process" and the court did not have jurisdiction to hear it.

A second person, South Gippsland resident and voter Gerard Donohue, has also lodged a petition challenging the VEC over the election's validity.

Surrounded by supporters outside court, Mr Donohue, of Korumburra, said he wanted to challenge the validity of the electoral writ itself.

Justice Gregory Garde will hear Mr Donohue's case after Ms Rigoni's.

The trial is continuing.