The State will submit a witness statement that there was non-stop fighting at athlete Oscar Pistorius' home on the morning his girlfriend Reeva Steenkamp was shot dead, the Pretoria Magistrate's Court heard on Wednesday.

"The accused's actions and phone calls on the night is part of pre-planning," State prosecutor Gerrie Nel said in Pistorius' bail application.

Pistorius is charged with the murder of the law graduate and model at his home in the early hours of February 14.

He has denied the allegation in an affidavit, but has not pleaded yet to the charge. He said he shot through a bathroom door, thinking there was an intruder, and not realising the person inside was Steenkamp.

In response to the defence's application for more information, Nel submitted a witness statement from the investigating officer Hilton Botha, who has been in the police service for 16 years.

The court heard that when he arrived at the house Steenkamp, who was wearing white shorts and a black vest, was already dead.

Asked whether he opposed bail for Pistorius, Nel said: Yes, because he is a flight risk."

He said they didn't want "another Dewani", referring to applications to extradite Shrien Dewani from the United Kingdom. Dewani is accused of murdering his wife Anni while on honeymoon in South Africa.

Nair asked Nel how serious the crime was.

"It's a very serious crime. A defenceless woman was gunned down," he said.

Click here for updates from DAY 2 of Oscar Pistorius' bail hearing