Related Rule
Practice Relating to Rule 44. Due Regard for the Natural Environment in Military Operations
The Report on the Practice of the Philippines states: “There are no specific rules which categorically state that the environment should be spared and protected during armed conflicts.” It refers to some information provided by non-governmental organizations, according to which, in most cases, the forest serves as a shield for civilians fleeing bombing, shelling and gun battles between combatants, resulting in damage to the area and the resources contained therein. 
Report on the Practice of the Philippines, 1997, Chapter 4.4.