Large swathes of the state will remain under the "Catastrophic" fire danger rating tomorrow.
The Rural Fire Service has also warned of a potential "catastrophic" fire danger warning on Sunday largely around the Hunter, from the coast, mid-north coast, out through the Central Tablelands, the top end of the greater Sydney region and out to the central west.
NSW RFS Superintendent Greg Sim said the fire at Georges Plains was started by a motor vehicle accident, but said no further details were available at this stage.
RFS Deputy Commissioner Rob Rogers said it would be tough day for many across the state.
In Sydney, where temperatures climbed into the high 40s on Saturday, it is now officially the hottest summer in the city on record, with 10 summer days over 35C, according to Bureau of Meteorology.
"We need to be clear that in catastrophic conditions, it is the most unsafe of conditions".
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But Toledo's lawyer Heriberto Benitez accused the judge of having a "vengeance" and said he would appeal against the ruling. Toledo is under investigation for money laundering in two different cases, Odebrecht and another case known as Ecoteva.
Mr Fitzsimmons warned the situation could get worse on Sunday, when winds are expected to sweep through the northern areas of New South Wales.
While no property losses were reported, the head of the Rural Fire Service says its warnings need to be taken seriously.
As the RFS chief spoke, 49 fires were burning across NSW, 17 of them uncontained.
He said any fire that started in catastrophic conditions would be "extremely hard to control".
Authorities in Australia are facing the "worst possible fire conditions" and have declared a "catastrophic" fire danger over the weekend with the country engulfed in a series record-breaking heat wave.
The state's northwest will cop the brunt of the extreme heat with Wilcannia, Ivanhoe, Bourke and Menindee forecast to reach 47C on Saturday.