CENTENNIAL, Colorado (AFP) - The father of a victim of the Colorado cinema massacre yelled "rot in hell!" at the alleged gunman on Friday, when a judge delayed officially charging him a day after ruling he stand trial.

Four or five people walked out of court after judge William Sylvester postponed for two months a hearing to arraign James Holmes, the 25-year-old who is accused of shooting 12 moviegoers dead and injuring at least 58 others.

Following preliminary hearings this week it was ordered on Thursday that Holmes will face trial over the late night massacre in Aurora, outside Denver, last July.

But the suspect's defence lawyers objected to the arraignment - the official laying of charges, when Holmes will enter a plea - on Friday, when it was meant to take place, and the judge postponed the hearing until March 12.

After the announcement several people left the court and shortly after Steve Hernandez, father of victim Rebecca Wingo, shouted "Rot in hell, Holmes!" prompting his immediate removal from the room by guards.

After the court settled he returned, and apologised. The judge told him: "I am so terribly sorry for your loss. I cannot imagine the emotions that must be raging." But he then asked Mr Hernandez to follow the court's rules of conduct.

The victim's father replied: "I meant no disrespect to your honour. I can promise no more outbursts." Holmes is accused over the July 20 shooting at a midnight screening of the Batman movie, The Dark Knight Rises. The massacre briefly revived America's perennial debate about gun control.

Witnesses said Holmes threw smoke bomb-type devices before opening fire randomly with weapons including an AR-15 military-style rifle, a 12-gauge shotgun and a .40-calibre pistol.

Over three days earlier this week, prosecutors called witnesses who gave chilling accounts of the slaughter, and played 911 emergency calls in which the chaos and loud booms of gunshots could be clearly heard.

Holmes' lawyers had been expected to present witnesses to bolster a case that he may be mentally unfit to stand trial.

But in the end they announced they would not, and the judge ruled on Thursday, in an order posted online, that prosecutors had established there was "probable cause" to believe the defendant committed the crimes.

During this week's preliminary hearing, the prosecution presented evidence that Holmes had planned the attack well in advance.

It included photos found on his iPhone suggesting he had surveyed the cinema weeks before the shootings. There were also several images showing him posing with guns and explosive devices hours before the massacre.

Holmes made at least 16 purchases from May to July 2012, including four firearms, incendiary devices and almost 6,300 rounds of ammunition, the court heard.

On Friday one of Holmes's defence lawyers, Tamara Brady, said she asked for the delay because of the time needed to go through evidence that consists of 30,879 pages of documents and more than 350 CDs and DVDs.

"We believe it will take until March to decide what is the appropriate plea in this case," she said, adding that it would give the defense time to decide if it will pursue a "not guilty by reason of insanity" plea.

Despite relatives' clear frustration at the delay, Mr Sylvester granted it due to "an abundance of caution, to avoid the possibility of being overturned on appeal and be back in here two years from now having to retry this case."

After the hearing, District Attorney George Brauchler stressed that Holmes was entitled to the usual standards of justice. "This is a mere accusation against the defendant," he told reporters.

"The defendant is entitled to presumption of innocence until proven otherwise," he added.