Practice Relating to Rule 72. Poison and Poisoned Weapons
In its written statement submitted to the ICJ in the Nuclear Weapons (WHO) case in 1995, Nauru stated:
Clearly it is a violation of customary international law to use poisons or other analogous substances. Thus even where a State is not a party to the Geneva Gas Protocol it is nonetheless bound under customary law to refrain from using poisonous weapons.