An emergency hearing was held in Melbourne earlier this month following a raid on the Marshall Road property.

The hearing was told property owners Les and Melinda Paxton had removed all but nine dogs from their farm since the raid on February 22.

When Animal Liberation Victoria visited the farm last month it found many dogs in horrific conditions, with puppies in cages and chained to cars surrounded by their own faeces.

It is believed that at one time, there were up to 59 dogs without a permit housed at the property.

The tribunal ordered the Paxtons to remove a further four dogs last week.

Mayor Pat Toohey told ABC news the owners had complied with the order to remove all but five dogs.

"The council inspected the property and were able to ascertain that there were four dogs remaining on the property plus one dog out with the owner," Cr Toohey said.

"The property owner had complied with the order from VCAT and we're very pleased that the welfare of the animals has been forefront in the decision-making process."

A second hearing will be held today at which the council will be pursuing the Paxtons over the use of the land for intensive animal husbandry for pigs and perhaps rabbits.

Council is also seeking an order for decommissioning the excess animal-keeping facilities, including a shipping container, and a permanent order regarding the dogs. The Paxtons represented themselves at the hearing. Lawyer Mathew Serwell appeared for Moorabool Shire

Council.