Victor Scott Brain, 39, was arrested after an early morning altercation in Dubbo.

Magistrate Andrew Eckhold said a king-hit had been alleged.

The solicitor representing Brain said the affray had involved two separate incidents and another person was yet to be charged.

"There was a push from behind and some punches,'' the solicitor said. "An alleged secondary incident was committed by another person. Closed-circuit television footage will be put before the court.''

Magistrate Eckhold said Brain had two other matters on his criminal record and full-time jail was on the cards.

The court heard Brain had been accepted into the Magistrate's Early Referral Into Treatment (MERIT) program.

MERIT provides an opportunity for adult defendants with substance abuse problems to work towards rehabilitation as part of the bail process.

Participants are closely case-managed by the MERIT team and the court receives regular progress reports.

Final hearing and sentence generally coincides with the completion of the MERIT program.

The affray charge was adjourned to January 29 for mention. Brain will reappear in court on March 6 for a MERIT progress report.