Introduction
Since the full-scale invasion in February 2022, Russia has systematically used drones in Ukraine to target both military objectives and civilian infrastructure in residential areas (PILPG, 2025). This article aims to discuss the legal framework of drone attacks.
The full-scale invasion not only changed the security situation but also caused large-scale suffering. In the armed conflict between Russia and Ukraine, new military strategies and technologies have been tested almost daily, particularly drones. Both Ukraine and Russia have used drones on a large scale, and it has, to some extent, changed the way wars are conducted today (Atlantic Council, 2024). Drones are a big part of Russian military strategy. One good example of their use is the Shahed drones, originally manufactured in Iran, which Russia is now also producing (Jensen, Atalan, 2025). These drones have been used almost constantly since the invasion. In early 2022, Russia was launching around 130 drone strikes per week, but this number has recently increased. By March 2025, the number had grown to more than 1,000 per week. It is worth mentioning that these drones are not only used for gathering intelligence, but they are also employed in attacks (CSIS, 2025). Some of them are used for specific strikes, while others, such as the kamikaze drones, are used to target military vehicles or even other drones.
This conflict has also shown the dual nature of drone use. Ukraine also uses drones, such as, small and cheap drones, used to defend territory and attack Russian positions (CSIS, 2025). These drones have helped Ukraine a lot, especially when it lacks artillery. On the other hand, Russia is using more advanced drones that are connected with other military systems (Toppo, 2025).
One of the biggest concerns around this topic is the use of drones against civilian areas. Many attacks have targeted civilians and civilian infrastructure. The use of drones is not illegal, but in warfare, the way they are used must be closely examined. Technologies change constantly, but international law, specifically the International Humanitarian Law (IHL) and International Human Rights Law (IHRL), remains the same. This article looks more closely at Russian drone strikes in Ukraine between 2022 and 2025 and whether they fit within the legal frameworks of IHL and IHRL.
Drone Strikes in Ukraine
Between 2022 and 2024, Russia carried out many drone attacks against civilian targets in Ukraine. One of the main targets has been the country’s energy infrastructure (IEA, 2024). By the middle of 2024, Ukraine had already lost almost two-thirds of its electricity generation capacity, and around half of its large substations were either destroyed or severely damaged (IEA, 2024). A very serious attack happened on August 26th, 2024, when Russia launched a massive attack using more than 200 missiles and drones. Most of them were aimed at power infrastructure, leaving around eight million households without electricity. Earlier attacks were also recorded. On October 10th, 2022, Russia targeted the Ukrainian power grid with 84 cruise missiles and 24 so-called suicide drones, including strikes on Kyiv (CNN, 2022). These attacks happened during the winter, when people needed heating and electricity the most.
However, it should be noted that it is not only the energy systems that were hit, as residential areas were also attacked with drones (AP News, 2025). In one major airstrike, which was called the largest single aerial assault of the war, Russia used 367 drones and missiles to hit more than 30 towns and villages. That attack killed at least 12 people and injured dozens more, especially in Kyiv (AP News, 2025). Human Rights Watch investigated four other attacks between February 1st and April 4th, 2025. These attacks killed at least 47 civilians and injured more than 180 people. The report said that the strikes were illegal under international law because they were either indiscriminate or too extreme compared to the military advantage (Human Rights Watch, 2025). Moreover, in Kherson Oblast, there are reports that Russian forces have used First Person View (FPV) drones to target civilians directly. Some of these drones are also dropped in places like playgrounds, streets, and public squares, which clearly are civilian areas (Logan, Coble, 2025). The evidence shows a clear pattern that these attacks are not just accidents or mistakes near the frontline, with civilian populations being targeted directly regularly (Amnesty International, 2024).
This is not the full list of Russia’s drone strikes in Ukraine since 2022, but the pattern of the drone attacks shows that civilians and civilian infrastructure are being targeted systematically. Although some attacks seem to have military goals, in the majority of cases, they aim to weaken Ukraine’s energy system and spread fear and panic among the civilian population. It can be argued that these repeated strikes on residential areas, energy networks, and civilians are a strategy that ignores the rules of international law. The applicability of legal frameworks to these drone strikes will be discussed in the next chapters.
Legal Framework
International Humanitarian Law (IHL)
IHL is a set of rules that were made to reduce suffering during armed conflicts. IHL primarily focuses on the actions that parties to an armed conflict can or cannot take, and more importantly, the rules of IHL are designed to protect individuals who are not participating in the hostilities (Melzer, 2019). Russia has been a party to the Geneva Conventions since 1949. Therefore, these rules, including their Additional Protocols, fully apply to the war in Ukraine, which qualifies as an international armed conflict (PILPG, 2025). When we are talking about whether the attack is legal under IHL, we should analyse if the attacks meet the requirements of the main principles of IHL.
It is important to note that drones are not prohibited under IHL, but what matters is how they are used and whether they comply with the basic rules of war.
The principles of IHL
The principle of distinction is one of the most important rules in IHL (Melzer, 2019). It requires that parties to an armed conflict distinguish between civilians and civilian objects and combatants and military objectives and direct military operations only against the latter (AP I, art. 48). Civilian places like homes, schools, and churches are protected unless they are clearly used for military purposes (art. 52). In the case of Ukraine, there is strong evidence that Russia has often violated this rule (Human Rights Watch, 2025). One of the clearest examples was the huge drone and missile attack on Kyiv Day, when 367 weapons hit more than 30 towns and villages (Kullab, Yeroshenko, 2025). Another serious case happened in February 2025, when a drone strike hit an apartment building in Poltava, killing 15 civilians (Human Rights Watch, 2025). These examples show that Russia has likely violated the principle of distinction when its drones target civilian infrastructure and objects. The UN Independent International Commission of Inquiry on Ukraine reported that Russian forces launched attacks with what they described as “apparent disregard for civilian life” (PILPG, 2025). In Kherson, FPV drones were reportedly used to target civilians directly (Logan, Coble, 2025). These drones even dropped mines in playgrounds and public areas, which clearly violates Article 51(2) of the Additional Protocol I, which says that civilians must never be the object of attack.
The prohibition on making civilians the object of an attack is a cornerstone of IHL, and it is also recognised as customary international law. If an attack is intended to spread terror among the population, it can be a serious violation of IHL. When we look at how often non-military targets are hit and how Russia’s drone strategy seems to be focused on punishing or scaring civilians, it becomes clear that the situation may be a case of deliberate attacks on civilians.
The principle of proportionality recognises that civilians may sometimes be harmed during attacks on military targets, but the expected harm to civilians must not be disproportionate to the military advantage expected from the attack (AP I, art. 51(5)(b)). There must be a balance between military needs and the duty to protect civilians. The principle of proportionality also says that all possible steps must be taken to avoid or reduce the harm to civilians (ICRC, 2009). Many drone attacks in Ukraine seem to go against this rule. For example, the attacks on Ukraine’s energy infrastructure potentially had some military nexus, but they also caused severe and widespread disruption to civilian life, including power outages and heating during the winter (Piper, 2024). The repeated high number of civilian deaths and the destruction of civilian buildings show that Russia is also violating the principle of proportionality.
The principle of precaution is another core principle of IHL. It requires all parties to the conflict to take every possible step to reduce harm to civilians and civilian objects during the attacks (AP I, art. 57). This may include choosing accurate weapons, warning civilians before an attack when possible, or changing and cancelling an attack if it is clear that the target is not a military objective and harm would be too high. Moreover, parties to the conflict should also make sure that military targets are not placed in crowded civilian areas. Russia has failed to uphold many of these responsibilities. Human Rights Watch reported that Russian forces did not give any warning to civilians before deadly drone strikes, which may constitute a violation of this principle (Human Rights Watch, 2025). When a state carries out repeated attacks that are indiscriminate or cause too much harm to civilians and fails to take precautions, it may indicate that the legal duties of the parties to the conflict are ignored.
International Human Rights Law (IHRL)
Besides, IHL, Russian drone strikes must also be assessed under IHRL. IHRL protects the basic rights and freedoms that all people have. These rights still apply during armed conflict, and states are not allowed to ignore them just because there is a war.
The right to life is one of the most important human rights. Article 6 of the International Covenant on Civil and Political Rights (ICCPR) states that every human has the right to life and no one should be arbitrarily deprived of it. The Human Rights Committee’s General Comment No. 36 gives a detailed explanation of this right. It says that the right to life not only prohibits killing but also includes protection from actions or even failures to act that could cause death, more specifically, states have the duty to protect lives. Furthermore, the committee has stated that “State parties engaged in acts of aggression as defined in international law, resulting in deprivation of life, violate ipso facto Article 6 of the Covenant”. States must not only avoid taking life arbitrarily, but they must also protect people from others who might do so.
Another important point is that this duty does not disappear in wartime. In fact, the right to life is non-derogable, which means that it cannot be taken away or suspended, even during war or national emergencies. Therefore, IHRL continues to apply with IHL during armed conflicts. The Human Rights Committee has also consistently repeated that the right to life is non-derogable. Thus, in Ukraine, even though there is an ongoing war, Russia still has to respect this right, and because Russia is using drones and carrying out attacks on Ukrainian territory, they have control over those actions and must follow human rights rules even outside their own borders.
In Ukraine, many of Russia’s drone attacks, especially those on homes and civilian infrastructure, have caused large numbers of civilian deaths and injuries. These attacks often happen far from the frontline and do not appear to serve any military purpose (Human Rights Watch, 2025). That means that they are most likely examples of arbitrary killings, which go directly against Article 6 of the ICCPR.
Conclusion
The use of drones in Ukraine shows how significantly the act of war has changed, but also how international law continues to be relevant. This article has looked at Russia’s drone strikes from 2022 to 2025 and examined them under the rules of both IHL and IHRL. While drones themselves are not banned, the way they are used often breaks the key rules of armed conflict. We saw many examples where Russia failed to respect the principles of distinction, proportionality, and precaution. Civilian homes, schools, and energy systems were attacked again and again, with no clear military goal. At the same time, IHRL, particularly the right to life under Article 6 of the ICCPR, remains applicable during war. Even in an international armed conflict, states must avoid arbitrary killings and protect human life. But many of the drone strikes examined here, especially those far from the frontlines, do not seem to follow this rule. When drones hit places like playgrounds or power plants during winter, killing civilians, the evidence shows serious violations not only of IHL but also of IHRL.
To sum up, it becomes clear that Russia’s drone campaign in Ukraine is not only a military strategy, but it also shows a pattern of ignoring international rules that are designed to protect civilians. While international law does not always move as fast as technology, the core ideas of protecting human life and reducing suffering must still guide how wars are fought. Otherwise, the gap between law and practice will only grow, and the human cost will be even greater.
Bibliography:
Amnesty International, ‘Ukraine 2024’ (Amnesty International, 2024) https://www.amnesty.org/en/location/europe-and-central-asia/eastern-europe-and-central-asia/ukraine/report-ukraine/ accessed 27 May 2025.
CNN, ‘The day war came back to all of Ukraine: Russia’s deadly missile attacks’ (CNN, 11 October 2022) https://edition.cnn.com/europe/live-news/russia-ukraine-war-news-10-10-22/index.html accessed 27 May 2025.
CSIS Military Fellows, ‘Insights for Future Conflicts from the Russia-Ukraine War’ (CSIS, 9 May 2025) https://features.csis.org/Insights-from-the-Russia-Ukraine-War/ accessed 27 May 2025.
Human Rights Watch, ‘Ukraine: Escalating Russian Attacks on Civilians’ (22 May 2025) https://www.hrw.org/news/2025/05/22/ukraine-escalating-russian-attacks-civilians accessed 27 May 2025.
International Committee of the Red Cross, Proportionality in Conduct of Hostilities (ICRC, 2009) accessed 27 May 2025.
International Covenant on Civil and Political Rights (adopted 16 December 1966, entered into force 23 March 1976) art 6 https://www.ohchr.org/en/instruments-mechanisms/instruments/international-covenant-civil-and-political-rights accessed 27 May 2025.
International Energy Agency, Ukraine’s Energy Security and the Coming Winter (IEA, 2024) https://www.iea.org/reports/ukraines-energy-security-and-the-coming-winter/ukraines-energy-system-under-attack accessed 27 May 2025.
Jensen B and Atalan Y, ‘Drone Saturation: Russia’s Shahed Campaign’ (CSIS, 13 May 2025) https://www.csis.org/analysis/drone-saturation-russias-shahed-campaign accessed 27 May 2025.
Kirichenko D, ‘Drone Superpower: Ukrainian Wartime Innovation Offers Lessons for NATO’ (Atlantic Council, 6 March 2024) https://www.atlanticcouncil.org/blogs/ukrainealert/drone-superpower-ukrainian-wartime-innovation-offers-lessons-for-nato/ accessed 27 May 2025.
Kullab S and Yeroshenko O, ‘Russia and Ukraine Complete Prisoner Swap Hours After Moscow Launches Major Aerial Assault’ (AP News, 26 May 2025) https://apnews.com/article/russia-ukraine-war-kyiv-dbefc3d0a83826c865908aa29dd40f93 accessed 27 May 2025.
Logan G and Coble KS, ‘Terrorizing Civilians and the Law of Armed Conflict’ (Lieber Institute, 4 March 2025) https://lieber.westpoint.edu/terrorizing-civilians-law-armed-conflict/ accessed 27 May 2025.
Melzer N, International Humanitarian Law: A Comprehensive Introduction (ICRC, 2019) accessed 28 May 2025.
Noone GP, Kyrychenko K, Scott T, Talukder G, Rindskopf L, Higgs B, Yang W and Kathawala R, ‘Targeting the Innocent: Russia’s Continued Attacks on Ukrainian Civilians’ (Lawyering Justice Blog, Public International Law & Policy Group, 6 May 2025) https://www.publicinternationallawandpolicygroup.org/lawyering-justice-blog/2025/5/6/russias-indiscriminate-attacks-on-civilians-in-ukraine accessed 27 May 2025.
Piper A, ‘Drones: Waging War on the Law’ (International Bar Association, 25 September 2024) https://www.ibanet.org/Drones-waging-war-on-the-law accessed 27 May 2025.
Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of International Armed Conflicts (Protocol I) art 48 https://www.icrc.org/sites/default/files/external/doc/en/assets/files/other/icrc_002_0321.pdf accessed 27 May 2025.
Toppo MS, ‘Drone Warfare in the Russia-Ukraine War’ (2025) 5(2) International Journal of Humanities Social Science and Management accessed 27 May 2025.
UN Human Rights Committee, General Comment No. 36: Article 6 of the International Covenant on Civil and Political Rights, on the Right to Life (30 October 2018) https://docs.un.org/en/CCPR/C/GC/36 accessed 27 May 2025.
