Practice Relating to Rule 15. The Principle of Precautions in Attack
The Russian Federation’s Regulations on the Application of IHL (2001) states:
The commander and staff while organising and conducting combat operations, firmly securing combat mission accomplishment, shall ensure respect of international humanitarian law, taking every possible precaution to avoid or if it is not possible, to minimize losses among the civilian population and damage to civilian property.
In 1995, in its judgment in the Situation in Chechnya case
, the Russian Federation’s Constitutional Court recognized the applicability of the 1977 Additional Protocol II to the conflict in Chechnya. The Court stated that in accordance with the Protocol, “every effort must be made to avoid causing damage to civilians and their property”.