Related Rule
Practice Relating to Rule 145. Reprisals
Section B. Reasonable notice and measure of last resort
In its judgment in the Hass and Priebke case in 1997, the Military Tribunal of Rome stated that, according to the unanimous views of writers, reprisals were legitimate only when they appeared as the only possible reaction because all possible means of identification and capture of the author of the unlawful act had been exhausted. 
Italy, Military Tribunal of Rome, Hass and Priebke case, Judgment in the Trial of First Instance, 22 July 1997, Section 4.
In its relevant parts, this judgment was confirmed by the Military Appeals Court and the Supreme Court of Cassation. 
Italy, Military Appeals Court, Hass and Priebke case, Judgment on Appeal, 7 March 1998; Supreme Court of Cassation, Hass and Priebke case, Judgment in Trial of Third Instance, 16 November 1998.