Related Rule
Croatia
Practice Relating to Rule 37. Open Towns and Non-Defended Localities
Croatia’s LOAC Compendium (1991) qualifies “unlawful attacks on … undefended localities” as war crimes. 
Croatia, Compendium “Law of Armed Conflicts”, Republic of Croatia, Ministry of Defence, 1991, p. 56.
Croatia’s Commanders’ Manual (1992) states that it is a commander’s duty to give relevant instructions concerning the protection of undefended areas when military activities are conducted in the vicinity of such areas. 
Croatia, Basic Rules of the Law of Armed Conflicts – Commanders’ Manual, Republic of Croatia, Ministry of Defence, 1992, § 48.
Under Croatia’s Criminal Code (1993), “indiscriminate attacks affecting … non-defended localities” are war crimes. 
Croatia, Criminal Code, 1993, Article 120(2).
Croatia’s Criminal Code (1997), as amended to 2006, states that a war crime is committed by “whoever violates the rules of international law in time of war, armed conflict or occupation by ordering [or committing] an attack against … undefended places”. 
Croatia, Criminal Code, 1997, as amended in June 2006, Article 158(2).
In the Perišić and Others case in 1997 in a trial in absentia before a Croatian district court, several persons were convicted of ordering the shelling of the city of Zadar and its surroundings on the basis of Article 25 of the 1907 Hague Regulations, common Article 3 of the 1949 Geneva Conventions and Articles 13–14 of the 1977 Additional Protocol II, as incorporated in Article 120 of Croatia’s Criminal Code. 
Croatia, District Court of Zadar, Perišić and Others case, Judgment, 24 April 1997.