Yugoslavia, Federal Republic of
Practice Relating to Rule 11. Indiscriminate Attacks
On the basis of two accounts of events during the conflict in Croatia, the Report on the Practice of the Federal Republic of Yugoslavia states:
There are many examples … of indiscriminate attacks of individual and collective character which both parties to the armed conflict in Croatia in 1991 and 1992 were pointing at. The mixed nature of this conflict, being both internal and international, contributed to this as well. Both parties referred to these incidents as violations of international humanitarian law. The fact that the parties did not question this norm [prohibiting indiscriminate attacks] when speaking about the behavior of the opposite side is a clear indication of their
opinio juris and a confirmation that such attacks were considered prohibited.