1 Title. Mark "criminal complaint" or "criminal private complaint." In judicial practice, there is a new line in the first item of the "Criminal Complaint" to explain who is prosecuting whom and what case:
(2) Basic information of the parties. First list the name, gender, age, ethnicity, place of origin, occupation (or position), unit or address of the private prosecutor.
(3) If the private prosecutor has an agent, after the private prosecutor is listed, another line should be listed to indicate the title of his agent, whether he is a legal agent, a designated agent or an authorized agent. After the title, list the agent's name, gender, age, ethnicity, place of origin, occupation (or position), unit or address, and relationship with the principal.
Secondly, the defendant’s name, gender, age, ethnicity, place of origin, occupation (or position), unit or address should be listed.
If there is more than one private prosecutor and defendant, they shall be arranged in order of primary and secondary circumstances. List the private prosecutor first, then list the defendants one by one.
The request is the "cause of action", which mainly explains the crimes stipulated in the criminal law, what crime the defendant has committed, and puts forward specific litigation requirements.
Facts and reasons are the main content of criminal private prosecution and an important basis for filing a lawsuit and requesting the People's Court to accept and hear the case in accordance with the law. It should be described clearly. It can be divided into three parts:
(1) Facts. Mainly write down the specific facts of the defendant’s criminal behavior against the private prosecutor (victim). The time, place, motive, purpose, means, circumstances and harmful consequences of the defendant's criminal behavior should be stated, as well as the relationship between the parties, the cause of the crime and the key issues of the case, so that the people's court can investigate, study, finalize and hear the case correctly.
2 reasons. The reasons section should list evidence. According to the provisions of the Criminal Procedure Law, the private prosecutor is obliged to provide evidence proving that the defendant has committed a crime. That is, for the criminal facts alleged in the criminal private prosecution, evidence must be produced so that the people's court can investigate and verify the evidence. On the basis of narrating facts and listing evidence, cite the corresponding provisions of the law to prove the nature and circumstances of the case, and compare it with the relevant provisions of the criminal law to explain what crimes the defendant has committed and the mitigating, aggravating, mitigating and aggravating circumstances.
When writing the reasons part, you should first express "emotion", then "reason", then "law", and finally introduce reasons to prove that the case is reasonable.
3 Conclusion. The main thing here is the final clear and specific purpose of the request. It can be written as: "To sum up, the behavior of defendant ××× violated the provisions of Article XX of the Criminal Law of the People's Republic of China, constituting the crime of XX, with serious consequences and egregious circumstances. It is requested that the defendant be punished in accordance with the law."