KwaZulu-Natal Legal Aid spokesman Bongani Mahlangu on Wednesday confirmed that the woman's lawyer had been informed of her death. He did not know the cause of death.
"The prosecution had contacted the practitioner that was dealing with the case and informed him of her death‚" Mahlangu said.
The pair were last in court in February‚ when a psychologist gave evidence about the mental state of the mother and daughter. The matter was due back in court in October.
The indictment presented at court detailed years of alleged abuse‚ which eventually led to the death of three-year-old Baby X in November 2014.
The child's mother‚ who was a sex worker‚ is alleged to have tried to sell Baby X for R100 when she was six months old.