Practice Relating to Rule 37. Open Towns and Non-Defended Localities
Section C. Attacks on open towns and non-defended localities
Italy’s IHL Manual (1991) qualifies “indiscriminate attacks against … non-defended localities” as war crimes.
Italy’s LOAC Elementary Rules Manual (1991) states:
Where protected zones or localities (… non-defended localities) have been agreed upon, the competent commanders shall issue instructions for action and behaviour near and towards such zones or localities.
The manual also provides that “protected zones shall be respected”.