More attention has been paid to fragmental utterances after Merchants (2004). Various ideas have been proposed for fragmental expressions in Korean as well. Ahn and Cho (2006) make a claim that fragments are all syntactically derived with ellipsis whereas Choi and Yoon (2009) propose that there are two different kinds of fragments in Korean: a Case-marked fragment (CMF) and a Caseless fragment (CLF). The latter approach is often called hybrid analysis. This paper is designed to review the so-called hybrid analysis about fragments in Korean and to provide it with a more crucial piece of evidence that Case is obligatory in ki-clausal fragments in Korean. The paper also examines different types of clausal fragments and makes an attempt to answer whether the clausal CMF and CLF have two different structures and what consequences we have with the claim.