One of WA's worst sex offenders will remain behind bars after the state's Chief Justice found that his "psychopathic" and "self-centred" personality meant he posed an unacceptable risk of committing further crimes, even against his own wife.

Key points: Garry Narkle has a criminal history stretching back 40 years for multiple rapes

Garry Narkle has a criminal history stretching back 40 years for multiple rapes He was arguing for his release after the end of his latest sentence

He was arguing for his release after the end of his latest sentence But the judge ruled he should remain detained for "control, care or treatment"

Garry Narkle, 64, was once described in State Parliament as "a serial sex monster" for his 40-year criminal history that includes violent sex offences against women, children and a man.

His 10-year jail sentence for his last offence — the rape of a homeless man in 2009 — expired earlier this year, but prosecutors argued in the Supreme Court he should be legally declared a "dangerous sex offender" and kept behind bars.

Chief Justice Peter Quinlan agreed, finding that while Narkle had already been punished for his crimes, there were "deeply entrenched features of [his] make up", including a "psychopathic personality", that made him a risk of committing further offences.

The woman met Narkle through an acquaintance in 2009. ( ABC News )

Chief Justice Quinlan said on the evidence before him, Narkle put his "own gratification" above "the safety, dignity and humanity of his victims" and there was "a significant likelihood" he would offend again.

"You are self-centred and indifferent to others. It is ... unlikely to change," he said.

'Abusive and controlling' relationship

One of the reasons prosecutors argued against Narkle's release was a concern that the 45-year-old woman who married him in jail in 2011, and who he planned to live with on release, would be added to his long list of victims.

The woman's identity is suppressed.

Chief Justice Quinlan said after listening to recorded prison phone calls between the two, and hearing evidence from the woman, it was his view their relationship on Narkle's side "was abusive and controlling".

Garry Narkle married the woman in prison in 2011. ( ABC News: Alkira Reinfrank )

He said Narkle belittled his wife in the calls and subjected her to "verbal abuse of the most appalling kind".

Narkle had "a persistent and unwavering suspicion" that she was being unfaithful and continually quizzed her about her movements, something Chief Justice Quinlan said showed Narkle's "controlling personality".

The couple met in 2009, three weeks before Narkle was taken into custody, and Chief Justice Quinlan said in the 10 years since then the woman had visited Narkle only two to three times a year, which meant their actual physical contact was "remarkably little".

He said she displayed a "lack of any real appreciation and comprehension" of her husband's criminal record, noting he had lied to her in the past and only recently given her "a piecemeal and inadequate" recounting of his history.

Supreme Court Chief Justice Peter Quinlan ruled Narkle should remain behind bars. ( ABC News: Briana Shepherd )

The woman testified that she did not have any fear of her husband and did not consider he would act in a violent way against her.

But Chief Justice Quinlan described that view as "ill-considered and unrealistic", saying he considered she would be placed in a vulnerable position if he was released.

"In the end I am left with grave concerns for the physical and emotional wellbeing of your wife if you were to live together," he said.

Under WA's Dangerous Sex Offender laws, the Chief Justice could have allowed Narkle to be released into the community on a strict supervision order with a range of conditions including constant electronic monitoring.

But he said given Narkle's record and his "anti-authoritarian attitudes", he could not be satisfied he would comply with any court orders and therefore he should be detained for "control, care or treatment".

Narkle appeared via video link from prison for the judgment.

His case will be reviewed again by the Supreme Court in a year.