(1) The basic information of the defendant, including name, sex, date of birth, place of birth and residence, ID number, nationality, education level, occupation, work unit and position, address, whether or not he has been subjected to criminal punishment, the type and time of punishment, and the situation of taking compulsory measures, etc. If it is a unit crime, the name, organization code, address and contact information of the criminal unit, and the names and addresses of the legal representative and litigation representative shall be stated.
(2) the cause of action and the source of the case.
(three) the facts of the case, including the time, place, process, means, motivation, purpose, harmful consequences and other factual elements related to conviction and sentencing. The basic elements of the alleged criminal facts described in the indictment should be clear and accurate. If the defendant is accused of multiple criminal facts, he shall list them one by one, and may summarize and describe the same crime with the same criminal means.
(4) The basis and reasons for the prosecution include the provisions of the criminal law committed by the defendant, the nature of the crime and the charges identified, the provisions of the punishment, the circumstances of the statutory lighter, mitigated or aggravated punishment, and the guilt of each defendant for the same crime.
Legal basis: Rules of Criminal Procedure of People's Republic of China (PRC) People's Procuratorate.
Article 392 If the people's court decides to hold a hearing, the public prosecutor shall make the following preparations:
(a) further familiar with the case, grasp the evidence;
(two) in-depth study of legal and policy issues related to this case;
(3) enrich the professional knowledge that may be involved in the trial;
(4) To draw up plans for interrogating defendants, witnesses, expert witnesses, people with specialized knowledge and reading, presenting and playing evidence, and to draw up plans for cross-examination;
(five) to draw up an outline to prove the legality of the evidence, and to prepare relevant materials to prevent disputes over the legality of the evidence;
(six) to formulate opinions on public prosecution and prepare an outline for debate;
(seven) it is necessary to make suggestions or cooperate with the people's court on the protection of witnesses appearing in court to testify, and make relevant preparations.
Article 393 The people's procuratorate shall examine the written materials submitted by the people's court or the defendant and his defenders, victims and witnesses before the court session. If it is put forward during the examination, arrest and prosecution, and it is verified that no evidence has been illegally collected, it shall notify the people's court, the relevant parties and defenders, and make good preparations for the trial according to the verified situation. For new materials or clues, supervisory organs and public security organs may be required to explain the legality of evidence collection or provide relevant certification materials.