Wagga District Court Judge Gordon Lerve on Friday adjourned the sentencing of Jennifer Louise Hay, aged 48, until December 13 in order to consider submissions from her barrister and Crown prosecutors.

Judge Lerve also said he needed to research past cases of manslaughter involving arson as it was "unusual" to see such offences come before the court.

"I am in uncharted territory at the moment as to what would be an appropriate sentence in terms of the numerical [time in jail]," Judge Lerve said.

In July this year, Hay pleaded guilty to charges of manslaughter and damage property by fire in relation to the incident at Kooringal just before 6am on February 25, 2019

Ms Green died from the fire at the Tichborne Crescent home while another woman managed to escape.

Originally, Hay was charged with murder and intentionally destroying property with intent to endanger a life last year following a police investigation into the fatal fire.

In court on Friday, defence barrister Eric Wilson submitted that Hay did not foresee the death of Ms Green when she set fire to a couch.

"For the plea of manslaughter, this is the objective test," Mr Wilson said.

Crown prosecutor Max Pincott submitted that there was "very little difference" between Hay setting fire to the couch, located on the patio, with a cigarette lighter or other source and her setting fire to the house itself.

"The couch was right up against the house," Mr Pincott said.

Hay appeared via video link from the Clarence Correctional Centre wearing a green prison uniform.

Neither the defence nor prosecution disputed Judge Lerve's assessment that Hay's offending was above the mid-range of seriousness.

Judge Levre asked Mr Wilson what his client planned to do on release.

Mr Wilson replied that Hay had a lot to think about and was doing courses in jail as she had never previously been employed for any length of time.

"She is a different person now, she looks and sounds different. Certainly different to the person on the body cam video for the arrest," Mr Wilson said.

NSW Police previously released a video of Hay's arrest in which she yelled at officers.

Mr Wilson submitted that "the stress [Hay] was under at the time" was a factor in determining moral culpability for the sentence.

Mr Pincott said he would not submit that Hay's motive in starting the fire was an aggravating factor.

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