Judge Keith Cutler has ordered the RSPCA to present a report on what happened to three of seven dogs taken into care after they were confiscated from Kathryn Hamilton Johnson of Poulshot, near Devizes, in December 2003.
Mrs Johnson, 56, was charged with seven counts of causing unnecessary suffering to the six pedigree rough collies and one border collie cross. She sent a message to Kennet Magistrates' Court when the case was due to be heard in October, saying she was unable to attend.
But the bench decided to go ahead with the case in her absence. They found it proved, although no defence case was put. They banned her from keeping animals for ten years and confiscated all seven dogs. She was given a two-year conditional discharge. There was no order made for costs.
Mrs Johnson applied to Salisbury Crown Court to appeal against conviction. She was particularly concerned that the dogs were not disposed of until she was able to put her case to the court.
The appeal was due to be heard on Monday. Judge Cutler said he was concerned to hear that, despite all assurances given to him personally, three of the dogs had been neutered and re-homed. The other four dogs are still in kennels near Ringwood in Hampshire. They have not been neutered.
He said: "I spoke to the RSPCA about this and if they have done something they shouldn't I will be very cross.
"I was assured that everything would be maintained so that, in the event of a successful appeal by Mrs Johnson, the seven dogs could be returned to her. I must find out who is responsible and I want a proper explanation."
He said that a contempt of court action was possible, which could result in a heavy fine or even imprisonment for whoever was responsible.
Mrs Johnson asked that the case be adjourned as her solicitor had withdrawn on Friday, leaving her without legal representation.
Mrs Johnson wishes to call evidence from a second vet who examined her dogs and came to a different conclusion than the RSPCA.
The RSPCA vet said all seven dogs were in greater or lesser stages of emaciation, but Mrs Johnson's vet has reported that only one dog was seriously underweight.
Mrs Johnson said she was already making arrangements to re-home up to five of her dogs when the RSPCA took action to remove them from her one-bedroom home in Poulshot.
Iain O'Donnell, barrister for the RSPCA, said they would prefer that the case went ahead on Monday. He said: "It is a charity and the main concern is about cost. The longer the case goes on, the more it is going to cost."
Judge Cutler said he understood the charity's position, but his duty was to endeavour to dispose of cases justly.
He and two magistrates sitting with him agreed to adjourn the case so that Mrs Johnson could get herself representation. A new date could not be set but the appeal is unlikely to be heard before May. After Monday's hearing the RSPCA agreed to allow Mrs Johnson to visit the four dogs that are being looked after at Ringwood.