Police in Victoria said he died when the tanker he was driving was hit by a falling tree, 20 kilometres (12 miles) from the town of Marysville, which was razed by fires that swept through the southern state last week.

"A large tree appears to have crashed onto one of our fire tankers at Cambarville, resulting in an ACT Fire Brigade firefighter confirmed dead," Australian Capital Territories Emergency Service Agency commissioner Greg Manson told reporters.

"Fortunately, no other firefighters were injured."

The firefighter, who has not been named, is the first emergency worker to die in the bushfire disaster.

The announcement of his death, confirmed by fire authorities, came hours after police raised the death toll from the fires to 200.

"Victoria (state) police believe the provisional fatalities from the 2009 bushfires have climbed from 189 to 200," a spokesman told AFP.

The update followed the discovery of an additional five bodies in the badly hit township of Kinglake, taking total deaths there to 37, and another three in the flattened hamlet of Marysville, where 39 people are now confirmed dead.

Another two bodies were found in Strathewen, where 42 people are now believed to have died, and one was discovered at Strath Creek.

Police have warned the toll is likely to rise further and it will take some time to reach a definitive figure.

Meanwhile the lawyer representing accused arsonist Brendan Sokaluk, said hate messages had been posted on social networking sites after the 39-year-old was named in court on Monday.

Julian McMahon told Victoria's Supreme Court that at least one relative of Sokaluk, who is in protective custody to guard him from vigilante attacks, had been threatened.

"Not only is there the understandable community anger which suddenly has a focus point, there's also vicious hatred appearing in another kind of medium," McMahon said, arguing for a ban on his photograph to remain in place.

"Facebook groups were showing my client's photo and calling for his torture and death."

"The safety of my client is of concern. There have been threats made to one family member at least that I'm aware of," McMahon added.

Sokaluk is accused of starting a fire that killed 11 people and razed 151 homes around Churchill, east of Melbourne, on February 7. He faces up to 25 years in jail if convicted.

With six fires still blazing in Victoria state, a battle over who pays for the damage was underway as a Singapore-owned power company also said it would fight compensation claims over one of the fires.

SP AusNet said Tuesday it would "vigorously defend" a lawsuit reportedly launched by survivors claiming a downed power line sparked a blaze that killed more than 100 people and destroyed about 1,000 homes in the Kinglake area of Victoria.

The claim against SP Ausnet, part of the Singapore Power Group, is expected to run to hundreds of millions of dollars, media reports said.

The company said only that it had been notified a writ was filed in the Victoria Supreme Court on Monday alleging that "faulty and/or defective power lines" caused loss and damage.

"SP AusNet believes the claim is both premature and inappropriate," the company said in a statement to the Australian stock exchange.

"However, SP AusNet will vigorously defend the claim," it said. "If the claim is pursued, SP AusNet advises that it has liability insurance which provides cover for bushfire liability."

A commission of inquiry into the fires has been charged with providing an interim report by August 17.

A Red Cross disaster relief fund has topped 100 million Australian dollars (65 million US dollars), with US pop singer Pink donating 250,000 dollars, joining other musicians such as Leonard Cohen who have also contributed.

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