Ram Singh, the driver of the bus in which the December 16 gang-rape took place, was the brain behind the brutal assault after which he tried to run the vehicle over the victim, and this would be included in the charge sheet, police sources said on Tuesday.
A nearly 1,000-page formal set of charges, likely to be filed in a court here January 3, is being made and would indicate that "the accused also tried to drive the bus over the rape victim and her male friend. Her friend pulled her to safety, just in time", said a police officer, refusing to be named.
Investigators have collected the forensic reports which mentioned that the woman bit three of the men who assaulted her. The bite marks on them are likely to be part of the prosecution evidence, he said.
The charge sheet would mention Indian Penal Code (IPC) provisions dealing with murder, gang-rape, sodomy, robbery, dacoity, attempt to murder, abduction and destruction of evidence, the officer said.
The formal set of charges would also rely on the victim's statements, made to two different judges in hospital, he said.
The charge sheet may highlight that Ram Singh, a short tempered man involved in criminal cases in the past, was instrumental in assaulting the 23-year-old victim and her 28-year-old friend with iron rod with the help of co-accused Akshay Thakur and a minor, the officer said.
The driver and Thakur would be the main accused to face charges of destruction of evidence as they washed the bus after the torture and murderous assault to remove all clues, the officer said.
The source said that the charge sheet would mention the role of all accused, including Ram Singh, his brother Mukesh, fruit seller Pawan Gupta, gym instructor Vinay Sharma and Thakur. They are in judicial custody.
A juvenile involved in the crime has been sent to a special home. All the accused were arrested over four days between December 17-21.
The officer said the charge sheet would indicate that "after the incident, Ram Singh and Akshay drove the bus to Noida where they washed the bus to erase the evidences. They also burnt the clothes that they removed from the victims' bodies," said the officer.
The minor accused was the one who initially started passing lewd comments when the young couple boarded the bus in south Delhi around 9.15 pm. He also was the first among the accused who used iron rod to assault the woman.
The charge sheet reports that the attackers were drunk and were on fun ride on the day of the incident. First, they brutally beat up the woman and her friend with an iron rod when they resisted their misbehaviour and then gang-raped the woman in the moving bus.
The woman fought the accused and bit Akshay Thakur, Ram Singh and Vinay Sharma.
An officer said they have collected all evidences against the accused and now they were waiting for the post-mortem examination report of the woman which was expected to be sent by Singapore-based Mount Elizabeth Hospital where she died on December 29.
The charge sheet, sources say, would cite around 30 to 40 witnesses, including the doctors who treated the gang-rape victim, both in Delhi and Singapore.
Ramadhar Singh, who was robbed by the six men on the bus minutes before they committed the gang-rape, would also testify as a witness. He was robbed of around Rs7,000 by the accused.
The charge sheet was being vetted by legal experts and police would seek death penalty for all the six attackers of the woman, the officer said.
The minor accused cannot be tried in court. A report will be sent to the Juvenile Justice Board, which will handle his case, the officer said.