An Australian Olympian and horse trainer charged with 92 animal cruelty offences after 22 horses were found dead on his Victorian property has been granted bail.

Neighbours found nearly two dozen dead horses on Sunday after looking for the source of a foul smell drifting from Batey Court in Bulla, about 35 kilometres north of Melbourne's central business district.

Twenty-two horses were found dead, another was put down and 20 more were suffering from malnutrition.

Bruce Akers, 63, is understood to have represented Australia as a wrestler at the 1972 and 1976 Olympic Games, and had been registered as a horse trainer, who last raced horses in 2011.

He competed as a welterweight in Munich and Montreal and lost all four bouts.

A stony-faced Mr Akers appeared via video link at the Broadmeadows Magistrates Court. Mr Akers did not speak as prosecutor Sergeant Jim Currell summarised the charges, telling the court that 22 horses had been found dead on the property with one other animal put down.

He said there were at least 20 horses still alive, however vets had found they were emaciated with a body scale index of 0.

"That is the lowest scale before a horses passes away," he told the court.

Sergeant Currell said a neighbour spotted one of the horses in distress with its "legs in the air", prompting them to call the RSPCA, a vet and the police for help.

A subsequent search of the property resulted in the grisly discovery of emaciated and dead horses in "various states of decay", Sergeant Currell said.

The court heard evidence that the bodies of the dead horses appeared to have been "piled up" by somebody.

Defence counsel Emily Buchanan said the horses did not belong to Mr Akers, who had been training and breeding horses since 1986. A title search shows the Batey Court property belongs to Mr Akers' daughter, Christy Akers.

Mr Akers suffered from several physical and mental conditions and should not be remanded in custody, Ms Buchanan said.

She also raised the prospect of asbestos-related material being dumped at a nearby tip that could have impacted the health of the horses.

"He was aware that the livestock were not healthy," she said.

Magistrate Rose Vella granted bail after enquires were made about whether Mr Akers would have access to any firearms.

She noted that the prosecution did not oppose bail as they did not believe there was a danger of him committing similar offences.

The bail conditions included restricting Mr Akers' access to the property and preventing him from caring for any animals in the future.

He will live at his daughter's house and is bailed to appear in court on May 2.

In granting bail, Magistrate Vella said Mr Aker faced the prospect of being imprisoned if found guilty of the charges.

"There is no doubt this is a very concerning case," she said.

It is understood Mr Akers could face up to two years in jail, a fine of up to $74,620 and be banned from owning any animal for at least 10 years, if he is found guilty of causing death by neglect.

Police and Country Fire Authority crews were performing the grim task of sorting through the animal carcases, with the help of State Emergency Service volunteers.

Police were trying to find carers for the malnourished horses and several were picked up later in the day, according to Channel 7.

The RSPCA revealed that it was warned about the horses being malnourished almost two weeks ago, but that its inspectors would not attend the property without a police escort because of safety concerns.

Jon McGregor, RSPCA Victoria's acting chief executive, said a "preliminary report" was received on March 22 indicating horses on the property did not have sufficient feed.

"We regret that this report didn't accurately describe the situation that was uncovered yesterday and that observations from outside the property did not reveal the true extent of what lay within," he said.

"This is an appalling situation. It is a tragedy that animals would be left to suffer in this way."

Mr McGregor said the agency had seized more horses in the past two months than at any other time in its 140-year history.

He said drought conditions were no excuse for the mistreatment of animals.

Racing industry figures said Mr Akers had been an owner-trainer, meaning he could not train horses owned by others.

He mostly ran horses in picnic meets, rather than at mainstream or TAB meetings.

Racing Victoria said on Monday afternoon that it had suspended Mr Akers' restricted training license, in light of him being charged with criminal offences. It would assist in relocating the remaining horses and help fund rehabilitation and feeding.

With Marissa Calligeros and Patrick Bartley