Serbia and Montenegro
Practice Relating to Rule 37. Open Towns and Non-Defended Localities
Section C. Attacks on open towns and non-defended localities
In its oral pleadings before the ICJ in the Application of the Convention on the Prevention and Punishment of the Crime of Genocide case (Bosnia and Herzegovina v. Serbia and Montenegro) in 2006, Serbia and Montenegro stated:
As regards the safe areas actually proclaimed by the Security Council, and to which the Applicant refers in its Reply (Chap. 5, para. 174), admittedly these should not have been exposed to armed attack. At the same time, however, they should have been completely disarmed in order to be completely protected.