Michael Angok, 30, did not apply for bail and it was formally refused by Judge Rachael Wong when the matter was mentioned in Blacktown Local Court on Monday,
The matter will return to court on June 5, according to court documents.
Angok, convicted of sexual assault on a 14-year-old girl in a Sydney gang rape in 2014, was being held in immigration detention when he escaped from Bankstown-Lidcombe Hospital on Wednesday, sparking a police manhunt.
Officers on Sunday tracked him to Seven Hills, in the city's northwest, where he was arrested after his shoes were allegedly found in a police search of a home in the suburb.
Angok had served his sentence for the offence against the teen, perpetrated in a park in the suburb of Doonside, and was being held in custody as an immigration detainee.
He was being transported from Villawood Immigration Detention Centre for medical treatment before he escaped,.
Australian Border Force declined to comment on the matter as it was before the courts, but said the "safety and security of the community remains the absolute priority for the ABF and Department of Home Affairs".
Home Affairs Minister Tony Burke did not respond to a request for comment.
Opposition home affairs spokesman Jonno Duniam said Angok's case showed a slide in security at federal immigration facilities.
"Escapes have more than doubled under Labor in only two years," Mr Duniam said in a statement.
"This points to a system that is clearly not being properly managed."
The issue of crimes committed by immigration detainees is controversial and evokes memories of the so-called NZYQ cohort , non-citizens detained indefinitely as a risk to the community then released after a 2023 High Court ruling deemed the detention unlawful.
The cohort's release grabbed headlines after the coalition seized on alleged reoffending to criticise the government for failing to keep them locked up following the High Court ruling.
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