R v AC – 2018 ONCA 333 (Hourigan):

[37] Like a trial judge’s decision on a severance application, a trial judge’s ruling in relation to
where an accused sits during his trial is discretionary, and this court should begin from a place of
deference: R. v. Lalande (1999), 138 C.C.C. (3d) 441 (Ont. C.A.). While the default placement of
an accused on trial is in the prisoner’s box, there is no presumption in this regard. In every case, the
accused’s placement must permit him to make full answer and defence, but the issue is to be
assessed on a case-by-case basis, having regard to the interests of a fair trial and courtroom security
in the particular circumstances of the case: Lalande.