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 / Updated  / Source: Reuters

Mass killer Anders Behring Breivik made a Nazi salute in court Tuesday where he was suing the Norwegian government, alleging it is violating his human rights by keeping him in isolation in jail.

It was the first time the 37-year-old right-wing extremist has been seen in public since 2012, when he was convicted of terrorism and mass murder for bomb and gun attacks that killed 77 people.

Breivik says the government has violated the European Convention on Human Rights by holding him in isolation in Skien prison, about 60 miles southwest of Oslo. The government has rejected his claims, saying he is being treated humanely and with dignity despite the severity of his crimes.

Anders Breivik gestures as he enters a courtroom in Skien, Norway, Tuesday.Lise Aserud / AP

With a dark suit and shaved head, Breivik was led into the gym-turned-courtroom in the prison, where the trial is being held for security reasons.

After prison guards removed his handcuffs, he turned to journalists covering the hearing and stretched out his right arm in a Nazi salute. Stone-faced, he remained there for a few seconds as guards stood idle and his lawyer Oystein Storrvik nervously took a sip of water.

During his criminal trial four years ago, Breivik entered the court with his own salute, using a clenched fist instead of the outstretched hand that the Nazis used to greet Adolf Hitler. At the time Breivik described himself as a modern-day crusader, fighting to protect Norway and Europe from Muslim immigration.

In violence that shocked Norway on July 22, 2011, Breivik set off a bomb in Oslo's government district and then carried out a shooting massacre at the annual summer camp of the left-wing Labor Party's youth organization.

Before the hearing started Tuesday, his lawyer, Oystein Storrvik, said the goal of the human rights case is to improve Breivik's prison conditions, including interaction with other prisoners and fewer restrictions on his mail correspondence.

Related: Norway Massacre Gunman Breivik Declared Sane

Breivik is held as the only inmate in a high-security wing of Skien prison. He has a three-room cell with a television and a computer but no Internet access. He is allowed some mail correspondence but it is strictly controlled and he's not allowed to communicate with other right-wing extremists.

He is allowed out into a yard for exercise. He only meets guards and medical personnel — even Storrvik has to speak to him through glass.

The government says the restrictions are well within the European Convention of Human Rights and are needed to make sure Breivik isn't able to build militant extremist networks from prison.

He is studying for a university degree from his cell.

In pre-trial documents, Oslo's Office of the Attorney General said "there is no evidence that the plaintiff has physical or mental problems as a result of prison conditions."

Norwegian authorities note that in a manifesto about his anti-Muslim views, Breivik wrote that "prisons are considered an ideal arena for which to recruit for political purposes."

The Associated Press contributed.