James Balcombe, 56, admitted using the false document to get out of attending the County Court on 11 arson charges in December 2018.

He was arrested last year in Perth, where court documents say he was living under the name Paul Johnson, and extradited to Melbourne in October.

Magistrate Justin Foster on Wednesday sentenced Balcombe to 14 days' jail for using the medical certificate to falsely claim he was recovering from plastic reconstructive surgery.

His ruse came unstuck when police contacted the surgeon's clinic, which said the document was a fake and Balcombe had never been a patient there.

"We cannot have people enlisting false documents full stop, but especially in the context of court proceedings," Mr Foster said.

"We have to be able to rely on proper doctors' certificates."

Balcombe's lawyer, Nick Jane, said his client had been dealing with personal turmoil, including a marriage breakdown, at the time.

He had been in hospital before the scheduled court date and made a "poor decision in the moment of anxiety" to get out of attending.

Mr Jane unsuccessfully sought for Balcombe to be punished with a fine.

He will remain in custody following his sentence, awaiting trial for eight counts of arson and three of attempted arson relating to jumping castles in 2017.

Australian Associated Press