Related Rule
Practice Relating to Rule 37. Open Towns and Non-Defended Localities
Section C. Attacks on open towns and non-defended localities
Kenya’s LOAC Manual (1997) provides that it is forbidden “to attack or bombard undefended towns, villages, dwellings or buildings”. 
Kenya, Law of Armed Conflict, Military Basic Course (ORS), 4 Précis, The School of Military Police, 1997, Précis No. 4, p. 2; see also p. 6.