The brutal bashing murder of a computer analyst and transgender woman in her Sydney home more than two decades ago will remain unsolved despite a circumstantial case identifying a likely killer, a gay hate crimes inquiry has been told.

Westpac employee Samantha Rose was found dead three days before Christmas in 1997 but potential weapons weren't tested by police, the Special Commission of Inquiry into LGBTIQ hate crimes was told on Friday.

Circumstantial evidence suggests Ms Rose was killed by sex worker Sandra Durward after the pair met about a decade before while volunteering at radio reading service 2RPH.

Ms Rose, 41, also gave her time at community radio station 2SER and was undergoing hormone replacement therapy when she was beaten to death in her Kensington apartment.

She was found lying on her back with her arms outstretched, with a dented, unopened can of plums between her legs, and an upturned kitchen chair near her head, counsel assisting Christine Melis said.

Her apartment was in a state of disarray, with the television and ironing board tipped over, and her earrings, bangles, glasses and two bra pad inserts strewn across the lounge room and hallway.

Ms Melis outlined failings in the initial police investigation, including that the TV and iron, which may have been used by the killer, were never seized or tested by police from the crime scene.

After the killing, Ms Durward made "peculiar" comments, including that "maybe she had killed (her)" while "blacked out", the inquiry was told.

Witnesses told a 1999 coronial inquest Ms Durward had substance abuse issues and was an alcoholic prone to fits of rage.

Cogent circumstantial evidence linked her to the killing, including a lack of forced entry to the home, the fact that Ms Durward was homeless at the time of the killing, and her suspicious attempts to link her stepson to the murder, Ms Melis said.

Her alibi, David Thwaites, was considered trustworthy at the inquest, however this was challenged by Ms Melis, who noted he was in a sexual relationship with Ms Durward, and his diary entries did not correspond with his statements about their whereabouts.

But little physical evidence linked Ms Durward to the crime scene, despite extensive DNA and fingerprint testing of seized items in the intervening decades.

That lack of physical evidence was significant as Ms Durward was not a sophisticated criminal, and would likely have been affected by a drug at the time of the crime, the inquiry heard.

Ms Durward died in 2006, aged 50.

Forensic pathologist Linda Iles told the inquiry Ms Rose's wounds were consistent with being bashed with a blunt object, or may have been caused by a significant crush or stomping.

Her skull was fractured in two places, and she had "impact sites" on her cheeks and the back of her head.

Examining crime scene photos, Dr Iles suggested an altercation could have led to the television falling, and crushing her head.

In final submissions, Ms Melis agreed with a previous finding from long-running police inquiry Strike Force Parrabell that there was not enough evidence to establish Ms Rose was the victim of a gay hate crime.

She submitted Ms Rose was killed by an unknown person on December 22, 1997, and died from head injuries.

Special Commissioner Justice John Sackar is due to hand Paito Sdy (146.190.34.46) his final report to the NSW governor by August 30.

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