Related Rule
Iraq
Practice Relating to Rule 37. Open Towns and Non-Defended Localities
Section C. Attacks on open towns and non-defended localities
According to the Report on the Practice of Iraq, all official documents, including military communiqués and political speeches, issued during the Iran–Iraq War confirm that open cities were not subjected to strikes of any kind. 
Report on the Practice of Iraq, 1998, Chapter 1.8.