Related Rule
Estonia
Practice Relating to Rule 155. Defence of Superior Orders
Estonia’s Penal Code (2001) provides:
The fact that the offence provided for in the present chapter [i.e. crimes against humanity, crimes against peace and war crimes] was committed pursuant to the order of a representative of public administration or of a military commander shall not preclude the punishment of the author of the crime. 
Estonia, Penal Code, 2001, § 88(2).