Practice Relating to Rule 37. Open Towns and Non-Defended Localities
Section C. Attacks on open towns and non-defended localities
In its judgment in the Shimoda case in 1963, Japan’s District Court of Tokyo stated:
Dropping an atomic bomb on undefended towns should … be deemed the same as blind bombing, if it is not an attack on defended towns. Such an act should be recognized as violating international law at that time.