When the public prosecutor file a charge to a court, there is a case at trial, and the adversary of the trial begins with the charge which requires the court to close the case. The public prosecutor goes to trial with the supplement in written or orally to expand or limit the charge filed already, which requires the court to confirm the scope of the charge. The practice of this aspect has long focused on the so-called principles of unitary and identity instead of addressing the said issues. To clarify issues of the supplement to prosecution, this study analyzes issues relating to the supplement to the prosecution and the scope of trial by properly limiting the power to supplement to prosecution to protect the right to counsel and the right to a fair trial.