A pathologist has told a Melbourne court he is "absolutely sure" Victorian woman Emma Bates died from a diabetes-related condition, not a head injury.

Michael Burke gave evidence during the fourth day of the committal hearing of John Torney, who is charged with negligent manslaughter over Ms Bates' death.

The 49 year-old was found dead in her Cobram home in April last year.

Dr Burke told the Melbourne Magistrates Court Ms Bates' cause of death was diabetic ketoacidosis — a life-threatening condition caused by a lack of insulin.

He said he also found injuries "classically" associated with head trauma, as well as older head injuries that were healing.

"There were no bruises to the brain and no evidence of brain swelling with herniation … but the head injury of itself did not cause death

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