A man accused of causing the deaths of 41 dogs at a rescue centre he ran refused to attend court, a judge said.
The animals were discovered during a raid at a property in Crays Hill near Billericay, Essex, on 13 May.
Police discovered the remains of four more dogs on 4 June, after a number of buildings at the site were dismantled.
Oaveed Rahman, 25, of Hope Road in the village, was due to appear at Southend Crown Court charged with three counts of fraud by false representation and two animal cruelty offences.
However, Judge Samantha Leigh said he refused to leave the prison cell he was remanded in and attend the hearing.
She adjourned proceedings until the week beginning 23 June.
Basildon Council launched an internal inquiry after the discovery, which also led to the seizure of 21 alive dogs in need of treatment.
A 25-year-old woman from London and another man who were arrested by police have been bailed until July.
They were prohibited from entering Hope Road and being in possession of any animal during that period.
