The government's refusal to communicate with Mr Freeman's mother, Narelle King, and the Aboriginal community was unjustifiable and unprecedented, Winnunga Nimmityjah chief executive Julie Tongs has told investigator Philip Moss.

The bashing, care, treatment and death of Mr Freeman had been characterised by secrecy and lack of accountability.

"Not a single request by Winnunga Nimmityjah or by his mother Narelle King over the 14 months between Steven Freeman's vicious bashing and his tragic death for information about the bashing, its investigation, his treatment or care has been met," she said. Ms Tongs has raised her concerns before but has now made a formal submission to Mr Moss's inquiry, which reports on October 31.

She asked Mr Moss to look into all aspects of Mr Freeman's treatment at the prison from the time he was remanded to await trial in April last year, to his bashing just hours later which left him in intensive care, to his treatment in the year following that until he died in prison in May this year. No cause of death has been released.

Former chief minister Jon Stanhope, under whose watch the prison was established, told Mr Moss it had failed to live up to the original plan as "the most human rights compliant, rehabilitation focused prison in the world".

It had a "lackadaisical approach" to rehabilitation. Aboriginal inmates described their time there as "characterised by boredom and a lack of opportunities for productive activity or work", Mr Stanhope said, asking Mr Moss to look at opportunities for detainees to work inside and outside the prison. He pointed to the auditor's finding that prisoners spent just five hours a week on rehabilitation compared with the planned 30.

While he was not suggesting drugs played a role in Mr Freeman's death, Mr Stanhope said the failure to set up a safe injecting room was indefensible and showed "a worrying failure of leadership".

The government had made it clear from the start that it wanted a safe injecting room, but it had been blocked by the union and staff. The government had a right to expect that staff employed at the prison would share its vision, he said.

"The AMC management has apparently, however, employed a workforce a majority of whom openly reject this declared objective of the AMC," Mr Stanhope, who works at Winnunga Nimmityjah, told Mr Moss. "That this has happened raises concern about both the leadership within ACT Corrections and the depth of commitment of the organisation and its staff to the government's ambitious aims and visions for the prison."

Human Rights Commissioner Helen Watchirs said Indigenous incarceration in the ACT was increasing at an alarming rate, up 17 per cent in the year to June, with a similar increase in the year before.

Overcrowding was a problem, with the prison operating at 127 per cent of capacity in 2014-15, posing problems for privacy and separation of sentence prisoners and remandees. The prison contained far more higher-security-risk and protected-status detainees that originally envisaged.

Detainee-on-detainee assaults had more than doubled from 5.31 per 100 detainees in 2013-14 to 12.56 per 100 detainees in 2015-16.

ACT Ombudsman Richard Glenn said he had received 99 complaints about the prison in the past two years, 83 from prisoners. They related to issues including disputes over rentals of equipment, perceived attitudes of corrections officers, access to programs and health services, concerns about heating, showers and phones, restrictions on visits, disputes about property, and the use of force, including strip searches. He was considering more oversight and inspections.