Practice Relating to Rule 37. Open Towns and Non-Defended Localities
Section C. Attacks on open towns and non-defended localities
The Russian Federation’s Military Manual (1990) states that “the bombardment by military aircraft or vessels of cities, ports, villages, dwellings or buildings … which are undefended and not used for military purposes” is a prohibited method of warfare.
The Russian Federation’s Regulations on the Application of IHL (2001) states: “objects protected by international humanitarian law
include … non-defended … zones … Attacks against such objects are prohibited by international humanitarian law with the exception of cases stipulated by this law.”