Practice Relating to Rule 13. Area Bombardment
Sweden’s IHL Manual (1991) states:
If the military objectives are located in a densely-populated area which has been evacuated only to a limited extent if at all, area bombardment may not be employed since this would be a breach of the basic rule prohibiting indiscriminate attack. Moreover, area bombardment would most probably lead to excessive injury and losses, and would thus be a breach of the proportionality rule.