Matthew Stewart faced the Ballarat Magistrates' Court last week for a plea hearing.

Police prosecutor Senior Constable Giles Brown said Stewart was linked to a stolen red Holden Statesman and a stolen black Holden Commodore.

He was captured on CCTV driving the cars between December 2019 and June 2020 at petrol stations around Ballarat.

The court heard he stole more than $300 worth of fuel in petrol drive offs.

Senior Constable Brown said Stewart was intercepted and found to be driving while disqualified and under the influence of methylamphetamine in January 2020.

In May 2020, police found Stewart with a black Holden Commodore that was stolen from the driveway of a Melbourne home in March.

Stewart told police he had purchased the car with cash and he denied all allegations in relation to both stolen cars.

Defence lawyer Sarah Wiltshire said it was conceded the offending was serious and aggravated because Stewart was on a community corrections order at the time.

She said Stewart had mental health issues and a long-standing drug problem, but she was instructed he had been drug free for a year.

Ms Wiltshire said Stewart had a traumatic history, anxiety, an intellectual disability and an acquired brain injury.

"The offending in 2019 correlates with his low mental state, the separation from the mother of his daughter and the battle to care for her," she said.

"His rehabilitation is a key factor to consider here. If a rehabilitative corrections order could be imposed this would give Mr Stewart the chance to address these issues."

Magistrate Ron Saines said Stewart had a history of persistent offending and he was disqualified from driving for four years in 2019.

"Your response to that has been about six occasions during the period of that disqualification you drove, you falsified number plates on a motor vehicle and engaged in petrol drive offs," he said.

"There is a significant need for denunciation and a message of deterrence for you. This falls into the question of whether a term of imprisonment is appropriate or not."

Mr Saines said he would defer sentencing for three months to obtain a report from Corrections Victoria about Stewart's compliance with his previous community corrections order.

Stewart will return to court in September.

"If there is further offending I make it clear to you I must consider imprisonment again," Mr Saines said.

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