Related Rule
Practice Relating to Rule 8. Definition of Military Objectives
According to the Report on the Practice of Japan, the judgment of the Tokyo District Court in the Shimoda case in 1963, which concerned the dropping of the atomic bomb, can be interpreted as having denied the existence of the concept of so-called quasi-combatants, whereby civilians who do not directly partake in hostilities, but indirectly contribute to hostile acts by working in transportation, communication and industrial facilities would be regarded as military objectives. 
Report on the Practice of Japan, 1998, Chapter 1.2, referring to Tokyo District Court, Shimoda case, Judgment, 7 December 1963.