Hashem Abedi would not leave the Old Bailey’s cells on Wednesday to face the parents and relatives of victims killed in the 2017 bombing.
The 23-year-old, who also refused to give evidence at his trial, will be jailed for 22 counts of murder after helping his brother Salman prepare for the attack.
Mr Justice Jeremy Baker: “I have required in this case Hashem Abedi to be brought to Central Criminal Court.
“My understanding is that, having been brought to this building, Hashem Abedi has refused to come into the courtroom.
“That is a matter for HM Probation Service rather than myself. Force cannot be used.”
Some victims’ relatives were in the Old Bailey, while others joined survivors to view the hearing by live link from Manchester, Leeds, Newcastle and Glasgow.
The court heard that Abedi would have been eligible for a whole-life sentence had he been over the age of 21 at the time of the Manchester Arena bombing, on 22 May 2017.
In March, Abedi was found guilty of 22 counts of murder, attempted murder of the injured survivors, and plotting to cause an explosion.
He denied all charges and initially told police he wanted to cooperate with them in order to prove his innocence, but was absent for much of his trial and sacked his legal team.
Investigators believe he may have masterminded the suicide bombing, which was carried out by his older brother Salman, but Abedi could not be questioned in court because he refused to give evidence.
Relatives of the victims read out emotional impact statements at Wednesday’s hearing.
The mothers of teenage sweethearts Chloe Rutherford and Liam Curry told of their devastation.
Lisa Rutherford said: “As a family we need answers – we are destroyed.”
Caroline Curry held up a photo of 19-year-old Liam and appeared to address some of her comments to the absent Abedi.
She said: “You took from me something more precious than gold, a beautiful boy, inside and out. I want you to look at Liam and remember the beautiful boy that was snatched away.
“Your actions have caused this heartbreak. I just feel cheated. You took his future, my future, my family’s future.”
Figen Murray, mother of 29-year-old Martyn Hett, described how she is now unable to go to bed until after 10.31pm, the time the bomb went off.