Соответствующая норма
Spain
Practice Relating to Rule 15. The Principle of Precautions in Attack
Spain’s LOAC Manual (1996) states: “Constant care shall be taken to spare the civilian population, civilian persons and civilian objects.” 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Publicación OR7-004, 2 Tomos, aprobado por el Estado Mayor del Ejército, División de Operaciones, 18 March 1996, Vol. I, § 10.8.e.(1); see also § 2.3.b.(2).
Spain’s LOAC Manual (2007) states:
In the conduct of military operations, constant care must be taken, to the extent possible, to spare the civilian population, civilians and civilian objects. …
The term “to the extent possible” means that the precautions should be practicable or practically possible, taking into account all circumstances prevailing at the time, including humanitarian and military considerations. 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Tomo 1, Publicación OR7–004, (Edición Segunda), Mando de Adiestramiento y Doctrina, Dirección de Doctrina, Orgánica y Materiales, 2 November 2007, § 4.3; see also §§ 3.1.d.(1) and 4.5.a.
In 2010, in the Couso case, which concerned the killing of a Spanish journalist in Baghdad on 8 April 2003 by troops of the United States of America, the Criminal Chamber of Spain’s Supreme Court noted:
[A]s alleged [by the appellants], the appealed order [presently under review] seems to place an emphasis, in order to terminate the proceedings, on the second section of Article 611(1) of the PC [Penal Code (1995)] when it is clear that on the last occasion the examining magistrate also based his proceedings on the first section referring to those who carry out or order an indiscriminate or excessive attack … [T]he latter should be evaluated by the Court, as was expressed in the dissenting opinion, according to the principles of International Humanitarian and customary law, and not in an anticipated manner. As a result the appealed order lacks the necessary reasoning, as it ignores the substantial grounds [raised] in the second indictment order …
In addition, the appealed order … reaches a conclusion concerning the termination of the proceedings in accordance with Article 637(2) LECr [Law on Criminal Prosecution of 1881] (as the facts did not constitute an offence) solely based on the allegation that there was a mistake by the acting [US] armed forces.
In this way, the order insists on the “credibility that there was a visual mistake concerning the presence of a sniper in the hotel, [and that this was] the reason that the decision to attack the building was [taken], in terms of prevention, in order to secure the area”. 
Spain, Supreme Court, Couso case, Judgment, 13 July 2010, Section II(II), Segundo, § 3, p. 8.
[emphasis in original]
The Court further referred to norms of IHL relevant to the case under review, including Article 51(1) of the 1977 Additional Protocol I, 
Spain, Supreme Court, Couso case, Judgment, 13 July 2010, Section II(II), Sexto, § 2, p. 14.
and restated Articles 57(1) and 85(3)(a) of the 1977 Additional Protocol I. 
Spain, Supreme Court, Couso case, Judgment, 13 July 2010, Section II(II), Sexto, § 2, pp. 15–16.
The Court also held:
The appealed decision declared the termination of the proceedings … as it considered that the “facts [of] the case did not constitute an offence” … [H]owever, the proceedings carried out do not permit sharing the conclusions of the first instance tribunal; rather, the facts [denounced] merit being subsumed under the cited penal provisions and the aforementioned norms of International Humanitarian Law. 
Spain, Supreme Court, Couso case, Judgment, 13 July 2010, Section II(II), Sexto, § 2, p. 16.
[emphasis in original]
In deciding upon a breach of the law due to the failure to apply the national and international provisions on the principle of precaution, the Court held:
1. … [T]here is no indication that the hotel was being used as a “shield” to commit an action against the accused, as was claimed by the Prosecution Service at one point and accepted by the appealed order. There is no trace – as opposed to what is stated in the order – that there was a visual mistake concerning the presence of a sniper … in the hotel. … [There is also no evidence] that the [US] tank was fired upon in the 35 minutes prior [to the attack on the hotel] or that there was anti-vehicle artillery capable of reaching it from the hotel, taking into account that the tank was more than 1500 metres away and that an RPG grenade launcher does not reach more than 650 metres. …
2. Due to their similarity with this matter, we must refer to what has been said in relation to the fifth and sixth issues raised by the previous appellants concerning the existence of rational indications of the commission of an offence which violate the ius in bello, namely the norms of International Humanitarian Law that must be observed by belligerents. 
Spain, Supreme Court, Couso case, Judgment, 13 July 2010, Section II(III), Octavo, §§ 1–2, p. 17; see also Section II(II), Sexto, § 2, p. 16.
[emphasis in original]
The Court upheld the appeal against the order of 23 October 2009 by the Third Section of the Criminal Chamber of the Spanish National Court, which declared the termination of the proceedings, and held that “the proceedings must continue, and the outstanding preparatory enquiries must be undertaken, as well as any others arising from the clarification of the events under investigation.” 
Spain, Supreme Court, Couso case, Judgment, 13 July 2010, Section III, pp. 20–21.
Spain’s LOAC Manual (1996) states: “The commander shall consider all precautions in order to avoid and, at least, to minimize civilian casualties and damage to civilian objects.” 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Publicación OR7-004, 2 Tomos, aprobado por el Estado Mayor del Ejército, División de Operaciones, 18 March 1996, Vol. I, § 10.8.d.(2).
Spain’s LOAC Manual (2007) states: “All feasible precautions must be taken to protect civilians and civilian property when carrying out attacks on military objectives.” 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Tomo 1, Publicación OR7–004, (Edición Segunda), Mando de Adiestramiento y Doctrina, Dirección de Doctrina, Orgánica y Materiales, 2 November 2007, § 2.3.b.(2).
The manual further states: “The parties to the conflict must attempt to minimize the number of civilian casualties and damage to civilian property that military operations may cause.” 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Tomo 1, Publicación OR7–004, (Edición Segunda), Mando de Adiestramiento y Doctrina, Dirección de Doctrina, Orgánica y Materiales, 2 November 2007, § 3.1.d.(4).
Spain’s Royal Ordinances for the Armed Forces (2009) states: “In the conduct of any operation, [members of the armed forces] must take into account the principle of distinction … in order to … avoid, as feasible, incidental loss of life, suffering, physical and material damage that may affect [the civilian population]”. 
Spain, Royal Ordinances for the Armed Forces, 2009, Article 111.
Spain’s LOAC Manual (2007) states:
Those responsible for planning and deciding on attacks must take “all feasible precautions” in the choice of means and methods of attack, with a view to “minimizing” the number of casualties among the civilian population, and “do everything feasible” to verify that the military objectives to be attacked are not protected persons or property. 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Tomo 1, Publicación OR7–004, (Edición Segunda), Mando de Adiestramiento y Doctrina, Dirección de Doctrina, Orgánica y Materiales, 2 November 2007, § 2.4.c.(6).
Upon ratification of the 1977 Additional Protocol I, Spain interpreted the term “feasible” as meaning that “the matter in question is feasible or possible in practice, taking into account all the circumstances prevailing at the time, including humanitarian and military aspects”.  
Spain, Interpretative declarations made upon ratification of the 1977 Additional Protocol I, 21 April 1989, § 3.
Spain’s LOAC Manual (1996) states:
Information is one of the basic pillars on which a commander must base his decisions. A commander needs information about the presence of protected persons and objects in the zone of operation, the nature and location of medical establishments, the location of cultural and religious objects, nuclear power plants, concentrations of civilian persons, movements of populations, etc. 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Publicación OR7-004, 2 Tomos, aprobado por el Estado Mayor del Ejército, División de Operaciones, 18 March 1996, Vol. I, § 2.3.b.(5); see also § 5.3.b.
Spain’s LOAC Manual (2007) states:
Information is one of the essential pillars on which commanders base their decisions. Commanders must include in their information requirements the presence in the area of protected people and property, the nature and location of medical establishments, the location of cultural and religious property, nuclear power stations, concentrations of civilian population, population movements, etc. 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Tomo 1, Publicación OR7–004, (Edición Segunda), Mando de Adiestramiento y Doctrina, Dirección de Doctrina, Orgánica y Materiales, 2 November 2007, § 2.3.b.(5); see also § 5.3.b.
Upon ratification of the 1977 Additional Protocol I, Spain declared with regard to Articles 51 to 58 inclusive:
It is the understanding [of the Spanish Government] that the decision made by military commanders, or others with the legal capacity to plan or execute attacks which may have repercussions on civilians or civilian objects or similar objects, shall not necessarily be based on anything more than the relevant information available at the relevant time and which it has been possible to obtain to that effect. 
Spain, Interpretative declarations made upon ratification of the 1977 Additional Protocol I, 21 April 1989, § 5.