The Victorian County Court has heard skylarking may have been the main reason for a soldier's death in 2009.

Private Anthony Brandt has been charged by police with dangerous driving causing death.

He was driving an armoured personnel carrier at the Puckapunyal Army Base in central-Victoria under the command of Private David Smith when the vehicle rolled, killing Private Smith.

The Victorian County Court has heard the pair were involved in a training activity, but in their spare time they attempted to perform hand-brake slides down a slippery grass slope.

The court heard due to the vehicle's design, Brandt had limited vision and relied on driving instructions from Private Smith, whose head was outside the turret.

The prosecution said witnesses reported the vehicle travelled faster on the pair's second attempt when Private Smith died.

Brandt's defence lawyer said he followed commands and the skill that was being practised was essential in wartime.

Colonel Roger Symons, the commanding officer of the School of Armour at the time of the incident, told the court the military viewed it as an accident and there was no explicit prohibition on hard turns at speed when the incident occurred.