Norma relacionada
Practice Relating to Rule 1. The Principle of Distinction between Civilians and Combatants
Section C. Attacks against civilians
According to Croatia’s LOAC Compendium (1991), “attacks on the civilian population” constitute grave breaches and thus war crimes. 
Croatia, Compendium “Law of Armed Conflicts”, Republic of Croatia, Ministry of Defence, 1991, p. 56.
Croatia’s Commanders’ Manual (1992) and Instructions on Basic Rules of IHL (1993) emphasize that attacks on civilians and civilian objects are prohibited. 
Croatia, Basic Rules of the Law of Armed Conflicts – Commanders’ Manual, Republic of Croatia, Ministry of Defence, 1992, § 10; Instructions “Basic Rules of International Humanitarian Law Applicable in Armed Conflicts”, Republic of Croatia, Ministry of Defence, 1993, § 7.
Under Croatia’s Criminal Code (1997), it is a war crime to commit or order the commission of “an attack against the civilian population … [or] individual civilians”. 
Croatia, Criminal Code, 1997, Article 158(1).
In the RA. R. case in 1997, the District Court of Split in Croatia sentenced 39 people, both soldiers and commanders, to prison terms ranging from 5 to 20 years on charges which included attacks on civilians. 
Croatia, District Court of Split, RA. R. case, Judgment, 26 May 1997.
In 1992, in a letter to the President of the UN Security Council, Croatia denounced direct attacks against the civilian population and civilian facilities carried out by “Serbs from Bosnia and Herzegovina and … from the UN Protected Area territories in Croatia”. Croatia considered that “the only aim of such an aggression is the destruction of civilian population and destruction of civilian facilities”, adding that “such acts are contrary to the provisions of Articles 51 and 52 of Additional Protocol I”. 
Croatia, Letter dated 24 August 1992 to the President of the UN Security Council, UN Doc. S/24481, 25 August 1992, p. 3.
The Report on the Practice of Croatia states that it is Croatia’s opinio juris that the duty not to attack civilians is part of customary international law. 
Report on the Practice of Croatia, 1997, Chapter 1.1.