What is the legal test for removing an accused from a trial?

Judicial interpretation of this provision is helpfully summarized by Jenkins J. in R v. Ross 2006 PESCTD 11: The jurisprudence supports the removal of an accused from a trial where it becomes necessary because the accused persistently disrupts the proceedings and frustrates the trial. The right of the accused is viewed as conditional upon the accused using the right for the purpose for which it was given, which is to advance and not defeat the course of justice and for the proper conduct of the trial. As to the frequency with which the power is to be exercised, it is viewed as a reserved power, to be exercised “exceedingly sparingly” and only in an obvious case and only where there is really no alternative. It is to be considered and exercised in harmony with our tradition of justice and values as reflected in the Criminal Code and the Charter. The exercise of the power is also viewed as temporary, to be limited to the duration necessary. … (at para. 51)