The brother of the Manchester Arena suicide bomber has refused to leave his jail cell for his two-day sentencing hearing.
Hashem Abedi, 23, was convicted in March of murdering 22 people in the 2017 Manchester terror attack.
Abedi was also convicted on one count of attempted murder, in relation to the survivors, and plotting to cause an explosion likely to endanger life.
His older brother, Salman, died in the attack after detonating explosives in a suicide vest.
Abedi was not present in court after he sacked his legal team halfway through the trial and refused to leave his prison cell.
The Old Bailey in central London heard on Wednesday that he helped his brother to plan the “sudden and lethal” attack that wounded hundreds of people, many of them children, at the end of an Ariana Grande concert on May 22, 2017.
Mr Justice Jeremy Baker said that Abedi was in the court building but not in court.
"I have no power to direct that force be used to compel him to come into court,” Mr Baker said.
He said it was a "matter for Parliament, who pass legislation which prevents the court of making a whole-life order in the circumstances of this case".
Mr Baker said Abedi remained legally unrepresented.
Individual tragedy recounted in court
Claire Booth, who survived the attack, broke down in tears as she read her victim statement in court.
Her sister, Kelly Brewster, 32, from Sheffield, was killed in the blast.
"I'm sad I've lost my sister and my sidekick," Ms Booth said. "We spent a lot of time together. I struggle with feelings of guilt.
"Christmas and other family celebrations are just not the same any more. Since May 22, 2017, our family has not been the same. All our hearts are broken.
"It seems cruel that her life has been cut short. My dad has not been able to walk his daughter down the aisle, my mum can't take her shopping for a wedding dress.
"We will never see her grow old. As a family, we have been thrown into a world of chaos."
Salman and Hashem Abedi were born in Manchester to a family of Libyan-born refugees who fled to the UK to escape the government of Muammar Qaddafi.
Hashem Abedi and his father were arrested in Tripoli by a local armed group called the Special Deterrence Force after the attack, but the father was released soon after.
After two years of legal disputes, Abedi was extradited to the UK last year and now faces a lifetime in jail.