Struggles broke out between police and more than a dozen members of the public, when a man appeared in Napier District Court on charges of assaulting and raping a girl.
Sahara Jayde Baker-Koro, aged five, was found dead in bed at a house in the suburb of Maraenui on the night of 20 December.
Police originally charged Kerry Ratana, 24, who lived at the house, with common assault, but added a charge of sexual violation at his second court appearance on Wednesday.
Just before the judge remanded him in custody until 2 February, members of the dead girl's family stood up and began yelling and screaming at the accused.
Several made physical threats and wrestled with police who prevented them reaching the dock.